EIN: 952077629
UEI: JC8EE8G4M5P5
Audited by: Almich & Associates
Oversight agency: 84 [Department of Education]
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 3, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by May 3, 2024 (847 days ago).
What is a management decision? →In 2 of 53 Federal Pell Grant files tested, the students were underawarded in Federal Pell Grant funds in the 2022-23 award year due to change in enrollment status. Student No. 1 was underawarded in the amount of $1,724. Student No. 2 was underawarded in the amount of $2,585.
Show full finding ▾Hide full finding ▴In 2 of 53 Federal Pell Grant files tested, the students were underawarded in Federal Pell Grant funds in the 2022-23 award year due to change in enrollment status. Student No. 1 was underawarded in the amount of $1,724. Student No. 2 was underawarded in the amount of $2,585.
The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.
In 7 of 53 Federal Pell Grant files tested, the students were overawarded in Federal Pell Grant funds in the 2021-22 and 2022-23 award years due to change in enrollment status.
Show full finding ▾Hide full finding ▴In 7 of 53 Federal Pell Grant files tested, the students were overawarded in Federal Pell Grant funds in the 2021-22 and 2022-23 award years due to change in enrollment status.
The institution does not dispute this finding. There was a change in personnel within the Registrar’s Office whereby proper training was not given to the staff member responsible for notification of enrollment changes to the Financial Aid department. This impacted the two students that were under-awarded Pell. Upon learning of this finding (and after disbursing the aid that was properly due), the issue was brought to the attention of senior leadership. The Registrar now sends out an electronic communication for all enrollment changes along with a document requiring signature from multiple departments (including Financial Aid). The Financial Aid department is also generating a weekly report that tracks all status changes from the prior week in order to make proper aid adjustments in a timely manner.
The Institution drew down $1,405,838 in HEERF – Student Portion funds in July 2021 but did not pay to students until April through November 2022.
Show full finding ▾Hide full finding ▴The Institution drew down $1,405,838 in HEERF – Student Portion funds in July 2021 but did not pay to students until April through November 2022.
The Institution does not dispute this finding. The Institution learned that it was not unique in misinterpreting the usage guidelines defined by the federal program. Upon learning that the interpretation was incorrect, the Institution immediately communicated with ED. These communications led to an accommodation from ED regarding the completeness of the Institution’s subsequent procedures. ED also permitted the Institution to retain the drawn down funds while it proceeded with disbursements to students between April and August 2022. In August 2022, the Institution returned the excess funds drawn down. Subsequent to August 2022, HEERF funds drawn down were in accordance with the federal program guidelines.
FAC accepted this audit on December 29, 2022 — management decision was due June 29, 2023.
FINDING NO. 2022-001: Ineligible Disbursement ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A dependent student was awarded a Federal Unsubsidized Direct Loan without documentation of a parent loan denial. Criteria Federal Unsubsidized Direct Loans are only available to dependent students when a loan to the student?s parents (PLUS) is denied or the file contains documentation of parents? inability to repay the parent loan. 34 CFR 685.203. Effect Of 76 files tested, 1 dependent student received a Federal Direct Unsubsidized Loan in the amount of $1,979 without appropriate documentation. The student was properly awarded all other aid received as a dependent student. Total questioned costs are $1,979. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, the Institution did not follow its procedures in properly making awards to students based on federal dependency status criteria. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2022-001: Ineligible Disbursement ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A dependent student was awarded a Federal Unsubsidized Direct Loan without documentation of a parent loan denial. Criteria Federal Unsubsidized Direct Loans are only available to dependent students when a loan to the student?s parents (PLUS) is denied or the file contains documentation of parents? inability to repay the parent loan. 34 CFR 685.203. Effect Of 76 files tested, 1 dependent student received a Federal Direct Unsubsidized Loan in the amount of $1,979 without appropriate documentation. The student was properly awarded all other aid received as a dependent student. Total questioned costs are $1,979. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, the Institution did not follow its procedures in properly making awards to students based on federal dependency status criteria. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.
FINDING NO. 2022-002: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect A Return of Title IV Funds payment was not paid within the required time frame for 1 of the 31 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 818 FDLP 11/4/21 1/6/22 1/25/22 19 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2022-002: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect A Return of Title IV Funds payment was not paid within the required time frame for 1 of the 31 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 818 FDLP 11/4/21 1/6/22 1/25/22 19 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute the finding. This was an isolated incident and no further instances of this nature occurred. There was a delay in processing the refund as the R2T4 was completed just before our holiday break. The staff member that handles the return in COD would have completed it upon return to the office in early January but then she was out of the office for longer than anticipated due to symptoms resulting from a positive diagnosis of Covid. Upon her return, she completed the refund and it posted to the ledger 19 days late. Each position within the department has now been cross trained so that any one staff member's extended absence does not impact the operation and our ability to maintain regulatory compliance. This finding as reviewed with all staff members in the department to ensure compliance moving forward.
FINDING NO. 2022-003: Refunds Not Performed ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV funds calculation was not performed when a student withdrew from an instructional program. Criteria Refunds for withdrawn students are to be properly calculated in accordance with applicable refund policies. 34 CFR 668.22. Effect Of 31 files tested for refund compliance, a Return to Title IV Funds calculation was not performed for 1 student at the time of withdrawal. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, procedures to ensure the proper completion of refund calculations and appropriate payment of resulting refunds due were not followed. Recommendation Due diligence and care must be exercised in completing refund calculations in accordance with SFA program requirements. Additional Information Upon learning of this finding, the Institution performed the Return of Title IV Funds calculation for the student. The calculation resulted in refunds due in the amounts of $1,485 to the student?s Federal Subsidized Direct Loan, $1,979 to the student?s Federal Unsubsidized Direct Loan, and $1,491 to the Federal Pell Grant Program. We reviewed the refund calculation and the return of funds documentation and found them accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2022-003: Refunds Not Performed ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2021-22 Statement of Condition A Return of Title IV funds calculation was not performed when a student withdrew from an instructional program. Criteria Refunds for withdrawn students are to be properly calculated in accordance with applicable refund policies. 34 CFR 668.22. Effect Of 31 files tested for refund compliance, a Return to Title IV Funds calculation was not performed for 1 student at the time of withdrawal. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance, procedures to ensure the proper completion of refund calculations and appropriate payment of resulting refunds due were not followed. Recommendation Due diligence and care must be exercised in completing refund calculations in accordance with SFA program requirements. Additional Information Upon learning of this finding, the Institution performed the Return of Title IV Funds calculation for the student. The calculation resulted in refunds due in the amounts of $1,485 to the student?s Federal Subsidized Direct Loan, $1,979 to the student?s Federal Unsubsidized Direct Loan, and $1,491 to the Federal Pell Grant Program. We reviewed the refund calculation and the return of funds documentation and found them accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. There was a personnel change in the staff member responsible for completing refund calculations. The automated notice for this particular student's withdrawal had been sent to the prior employee, who by that time was no longer with the college. The new individual did not see the notice and was not aware that a refund calculation was required. There was a brief window when all notifications were switched to the new staff member, and this particular status change was processed during that transition. The refund has now been processed and all unearned aid for the term has been returned. We have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with all staff members in the department to ensure compliance moving forward.
2021-003
FAC accepted this audit on December 30, 2021 — management decision was due June 30, 2022.
FINDING NO. 2021-001: Common Origination and Disbursement system (COD) Discrepancy - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition Reconciliation of FDLP disbursement dates in the Common Origination and Disbursement system (COD) with the Institution?s records was not performed during the Institution?s fiscal year ended March 31, 2021. Criteria Reconciliation of student disbursement data and/or transmission adjustments of rejected records are required to be submitted to COD within 15 days of payment or of the Institution becoming aware of the need to make an adjustment. Additionally, FDLP disbursement dates in COD are required to match the Institution?s records (34 CFR 668.164(a) and 34 CFR 690.83). Effect Of 65 FDLP records tested, 65 students? Federal Direct Loan Program disbursement dates in COD differed from the Institution?s records. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution did not complete reconciliation of FDLP disbursement dates in COD with the Institution?s records. Recommendation The Institution should adhere to its policies of reconciliation of FDLP disbursement dates in COD with the Institution?s records. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-001: Common Origination and Disbursement system (COD) Discrepancy - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition Reconciliation of FDLP disbursement dates in the Common Origination and Disbursement system (COD) with the Institution?s records was not performed during the Institution?s fiscal year ended March 31, 2021. Criteria Reconciliation of student disbursement data and/or transmission adjustments of rejected records are required to be submitted to COD within 15 days of payment or of the Institution becoming aware of the need to make an adjustment. Additionally, FDLP disbursement dates in COD are required to match the Institution?s records (34 CFR 668.164(a) and 34 CFR 690.83). Effect Of 65 FDLP records tested, 65 students? Federal Direct Loan Program disbursement dates in COD differed from the Institution?s records. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting the non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution did not complete reconciliation of FDLP disbursement dates in COD with the Institution?s records. Recommendation The Institution should adhere to its policies of reconciliation of FDLP disbursement dates in COD with the Institution?s records. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. There was an issue with our internal student information system (CampusVue) aligning posting dates on the ledger with that of COD. Subsequently, the date on the ledger reflected the GS drawdown date and not the disbursement date in COD. The college had to troubleshoot the issue with the vendor, and has since resolved the issue. Our Financial Aid Operations Manager now requests payments for GS drawdowns prior to disbursing via COD. Once payments are posted to the ledger, CVUE creates disbursement date adjustments for export to COD.
FINDING NO. 2021-002: Late Return of Ineligible Funds ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 Statement of Condition Ineligible funds were not returned in a timely manner for certain students. Criteria Ineligible disbursements credited to student accounts are to be returned to the appropriate Title IV program within 30 days of the later of the determination date or the date the funds were delivered to the student?s tuition account. (34 C.F.R. 668.21). Effect In 2 of 76 files tested, 2019-20 award year ineligible Title IV funds were not returned within the required time frame. For both students the Institution did not timely discover that the disbursements should not have been made and the funds needed to be returned to the respective Title IV sources. Therefore, this finding represents a significant deficiency in internal control. The payments associated with this finding are as follows: Student No. Title IV Program Amount Due Due Date Date Returned 1 PELL $ 1,848 5/21/20 7/28/20 FSEOG 50 5/21/20 7/28/20 2 FPLUS 6,569 5/9/20 5/19/20 FDLP 1,980 5/9/20 5/19/20 Cause The Institution?s internal control did not function as designed and therefore, procedures to ensure timely returns of ineligible funds were not followed for these students. Recommendation The Institution?s control procedures for processing ineligible funds payments should be closely followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-002: Late Return of Ineligible Funds ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 Statement of Condition Ineligible funds were not returned in a timely manner for certain students. Criteria Ineligible disbursements credited to student accounts are to be returned to the appropriate Title IV program within 30 days of the later of the determination date or the date the funds were delivered to the student?s tuition account. (34 C.F.R. 668.21). Effect In 2 of 76 files tested, 2019-20 award year ineligible Title IV funds were not returned within the required time frame. For both students the Institution did not timely discover that the disbursements should not have been made and the funds needed to be returned to the respective Title IV sources. Therefore, this finding represents a significant deficiency in internal control. The payments associated with this finding are as follows: Student No. Title IV Program Amount Due Due Date Date Returned 1 PELL $ 1,848 5/21/20 7/28/20 FSEOG 50 5/21/20 7/28/20 2 FPLUS 6,569 5/9/20 5/19/20 FDLP 1,980 5/9/20 5/19/20 Cause The Institution?s internal control did not function as designed and therefore, procedures to ensure timely returns of ineligible funds were not followed for these students. Recommendation The Institution?s control procedures for processing ineligible funds payments should be closely followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. The first student took an LOA mid-winter term and then returned in the spring term to the same classes. Funds were posted to the account in the usual disbursement process, and it was not until the next scheduled disbursement in the summer term that it was discovered that the courses from spring were the same as winter. Since the student was not eligible for the spring disbursement for duplicate courses, the awards were scheduled for immediate return. Staff has been trained on the importance of reviewing courses for LOA students prior to disbursing aid to ensure that funds are not being posted for duplicate courses. This audit finding and institutional LOA policy was reviewed with the department to ensure compliance moving forward. The second instance involved funds posted for a student that did not attend class during add/drop and was considered a non-enrollment for the term. The institution pulled in aid for this student prior to add/drop, but due to personnel shortages due to the pandemic, we were unable to conduct the review process until two weeks later than usual. This resulted in the return of ineligible funds not being completed until I0 days after the required 30-day requirement. The institution recognizes the risk of pulling in funds prior to add/drop, and has now adjusted our policy so that all disbursements are completed after verification of attendance is completed following the add/drop deadline. This finding was reviewed with department personnel to stress the importance of timely return of ineligible funds.
2020-004
FINDING NO. 2021-003: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect Return of Title IV Funds payments were not paid within the required time frame for 1 of the 19 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 1,030 FDLP 4/2/21 5/17/21 7/5/21 49 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-003: Late Refunds ? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition A Return of Title IV Funds payment for one student was not made in a timely manner. Criteria The U.S. Department of Education requires that refunds made electronically under the Return to Title IV Funds provisions be returned within 45 days of a student?s official withdrawal date to be considered timely. (34 CFR 668.22.) Effect Return of Title IV Funds payments were not paid within the required time frame for 1 of the 19 student files tested for refund compliance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. The late payment associated with this finding is: Amount of Refund Program Paid Withdrawal Date Refund Due Date Refund Date Days Late $ 1,030 FDLP 4/2/21 5/17/21 7/5/21 49 Cause In this instance of noncompliance, the Institution?s internal control did not function as designed and therefore the Institution?s procedures for processing refunds and Return of Title IV Funds payments were not followed. Recommendation The Institution should take steps to ensure that its procedures for the timely disbursement of refunds and Returns of Title IV Funds payments are strictly followed. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The person tasked with conducting R2T4 refund calculations inadvertently missed completing the calculation for this one student and did not identify the issue until the following month after the 45-day deadline. It was brought to the attention of management and the refund was completed immediately upon notification. The individual is no longer employed by the college. We now have two personnel trained on completing/reviewing R2T4 calculations to serve as a checks-and-balance within the department. This finding was reviewed with both staff members to ensure compliance moving forward.
FINDING NO. 2021-004: Enrollment Statuses and Status Effective Dates Not Reported to NSLDS? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 and 2020-21 Statement of Condition The Institution did not always report the enrollment statuses and status effective dates to the National Student Loan Data System (NSLDS) for certain students. Criteria Institutions are required to accurately report a student?s changes in enrollment status and notify NSLDS within 60 days of a student?s change in enrollment status. The Institution may utilize a Roster file (formerly called the Student Status Confirmation Report) for notification if the report will be submitted within 60 days of the status change. Accurate and timely reporting of student status changes is essential because the last day of attendance on at least a half-time basis triggers the beginning of the borrower?s grace period. Incorrect reporting of student status changes may result in federal interest subsidies being paid toward loans that should be in repayment and are no longer eligible for the subsidies. (34 CFR 685.309(b)). Effect Of 65 FDLP files tested, 4 students? enrollment statuses and status effective dates were not reported to NSLDS. Additionally, the enrollment status effective dates were not updated in a timely manner for 3 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution?s procedures with respect to accurate and timely reporting to NSLDS of borrowers? enrollment status changes and effective dates were not always followed. Recommendation The Institution needs to follow its procedures to ensure that student enrollment status and effective date changes are reported correctly and timely to NSLDS. Additional Information Upon learning of this finding, the Institution updated the enrollment statuses and status effective dates for the 4 students. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-004: Enrollment Statuses and Status Effective Dates Not Reported to NSLDS? Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 and 2020-21 Statement of Condition The Institution did not always report the enrollment statuses and status effective dates to the National Student Loan Data System (NSLDS) for certain students. Criteria Institutions are required to accurately report a student?s changes in enrollment status and notify NSLDS within 60 days of a student?s change in enrollment status. The Institution may utilize a Roster file (formerly called the Student Status Confirmation Report) for notification if the report will be submitted within 60 days of the status change. Accurate and timely reporting of student status changes is essential because the last day of attendance on at least a half-time basis triggers the beginning of the borrower?s grace period. Incorrect reporting of student status changes may result in federal interest subsidies being paid toward loans that should be in repayment and are no longer eligible for the subsidies. (34 CFR 685.309(b)). Effect Of 65 FDLP files tested, 4 students? enrollment statuses and status effective dates were not reported to NSLDS. Additionally, the enrollment status effective dates were not updated in a timely manner for 3 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution?s procedures with respect to accurate and timely reporting to NSLDS of borrowers? enrollment status changes and effective dates were not always followed. Recommendation The Institution needs to follow its procedures to ensure that student enrollment status and effective date changes are reported correctly and timely to NSLDS. Additional Information Upon learning of this finding, the Institution updated the enrollment statuses and status effective dates for the 4 students. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. There were some personnel issues related to the COVID-19 pandemic that prevented appropriate implementation of our enrollment reporting process. We have tightened up our policy and assigned designated staff to conduct regular updates to the enrollment status at the start of the term, at check points throughout the term, and at the end of the term. Our Registrar is fully trained and experienced with SSCR reporting. Our Financial Aid Manager is receiving automated notifications to update NSLDS when a status changes to LOA, withdrawal, or dismissed. The entire FA department was given training on proper protocols and the importance of timely enrollment reporting.
2020-005
FINDING NO. 2021-005: Federal Pell Grant Overpayment ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 Statement of Condition Certain students were overawarded in Federal Pell Grant funds. Criteria An institution is required to pro-rate Federal Pell award amounts, perform need analysis calculations, and review prior aid history to ensure that students are appropriately awarded. (34 CFR 690.79.). Effect In 2 of 46 Federal Pell Grant files tested, the students were overawarded in 2019-20 Federal Pell Grant funds. Student No. 1 was overawarded in the amount of $517. Student No. 2 was overawarded in the amount of $1,033. Both students were overpaid due to a change in enrollment status. Total questioned costs are $1,550. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, internal control did not function as designed and the Institution did not follow its procedures with respect to the awarding of Title IV funds. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Additional Information Upon learning of this finding, the Institution returned $1,550 to the Federal Pell Grant Program. We reviewed the repayment documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-005: Federal Pell Grant Overpayment ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2019-20 Statement of Condition Certain students were overawarded in Federal Pell Grant funds. Criteria An institution is required to pro-rate Federal Pell award amounts, perform need analysis calculations, and review prior aid history to ensure that students are appropriately awarded. (34 CFR 690.79.). Effect In 2 of 46 Federal Pell Grant files tested, the students were overawarded in 2019-20 Federal Pell Grant funds. Student No. 1 was overawarded in the amount of $517. Student No. 2 was overawarded in the amount of $1,033. Both students were overpaid due to a change in enrollment status. Total questioned costs are $1,550. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, internal control did not function as designed and the Institution did not follow its procedures with respect to the awarding of Title IV funds. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Additional Information Upon learning of this finding, the Institution returned $1,550 to the Federal Pell Grant Program. We reviewed the repayment documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. Both incidents were from the 2019-20 award year, during a time when we had just transitioned from a 3rd party servicer to in-house processing. The Student Information System (CampusVue) was incorrectly calculating the enrollment status for some students based on the timing of when they started a new academic year. Internal staff reviewed the settings and were able to adjust the configuration so that the enrollment status accurately reflected the borrower based academic year. This allowed our Financial Aid Operations Manager to disburse and return aid based on the correct enrollment status. Funds were returned and proof was provided at the time of the audit. Since making this adjustment, no further instances of this nature occurred in the 2020-21 award year. The finding has been reviewed with department staff for ongoing training purposes.
FINDING NO. 2021-006: Federal Grant Underpayments ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition One student was underpaid Title IV funds. Criteria Higher education institutions were not required to return Title IV funds to the federal program source on behalf of students who withdrew as a result of COVID-19 circumstances for any student who began attendance in a payment period or period of enrollment that included March 13, 2020, or began between March 13 and the later of December 31, 2020 or the last date that the national emergency is in effect (Federal Student Aid Electronic Announcement dated May 15, 2020, updated June 16, 2020). Effect In 1 of 18 withdrawn student files tested, the student was underpaid in 2020-21 Federal Pell Grant funds in the amount of $2,115 and in Federal Supplemental Educational Opportunity Grant funds in the amount of $200. The student was underpaid as the Institution returned the funds at the time of the student?s withdrawal, although the student was eligible per U.S.D.E.?s COVID-19 guidance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this instance of noncompliance, the internal control did not function as designed and the Institution did not follow its procedures with respect to retention of Title IV funds for a withdrawn student. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately paid. Additional Information Upon learning of this finding, the Institution paid the underpayment in the amount of $2,315 to the former student with institutional funds. We reviewed a copy of the student ledger and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-006: Federal Grant Underpayments ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition One student was underpaid Title IV funds. Criteria Higher education institutions were not required to return Title IV funds to the federal program source on behalf of students who withdrew as a result of COVID-19 circumstances for any student who began attendance in a payment period or period of enrollment that included March 13, 2020, or began between March 13 and the later of December 31, 2020 or the last date that the national emergency is in effect (Federal Student Aid Electronic Announcement dated May 15, 2020, updated June 16, 2020). Effect In 1 of 18 withdrawn student files tested, the student was underpaid in 2020-21 Federal Pell Grant funds in the amount of $2,115 and in Federal Supplemental Educational Opportunity Grant funds in the amount of $200. The student was underpaid as the Institution returned the funds at the time of the student?s withdrawal, although the student was eligible per U.S.D.E.?s COVID-19 guidance. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this instance of noncompliance, the internal control did not function as designed and the Institution did not follow its procedures with respect to retention of Title IV funds for a withdrawn student. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately paid. Additional Information Upon learning of this finding, the Institution paid the underpayment in the amount of $2,315 to the former student with institutional funds. We reviewed a copy of the student ledger and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. A refund calculation was performed after a student was dismissed due to 14 consecutive days of non-attendance, and the Pell & SEOG were returned back to ED as is protocol. The student's reason for withdrawing turned out to be COVID-19 related, and as such the institution should have retained these disbursements of Pell and SEOG on the account. Upon discovery, the student was given a grant from the institution in the equivalent amount of $2,315 (proof was provided at the time of the audit). The Federal Student Aid Electronic Announcement dated May 15, 2020, with update on June 16, 2020, was reviewed with internal staff for training purposes and to prevent findings of a similar nature in the future.
2020-006
FINDING NO. 2021-007: Late Exit Counseling - Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition Federal Direct Loan Program (FDLP) exit counseling was not always performed in a timely manner. Criteria All institutions must conduct exit counseling to inform each FDLP borrower of their rights and obligations as a borrower within 30 days of the official withdrawal or graduation date determined by the institution. Documentation of the exit counseling must be maintained in each borrower?s file. (34 C.F.R. 685.304(b)). Effect In 4 of 65 FDLP files tested, the documentation indicated that exit counseling was not performed in a timely manner. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution's procedures for counseling FDLP borrowers in a timely manner were not applied. Recommendation The Institution should adhere to its procedures with respect to providing borrowers with FDLP exit counseling in a timely manner and maintaining documentation in the student files. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-007: Late Exit Counseling - Significant Deficiency in Internal Control and Instances of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition Federal Direct Loan Program (FDLP) exit counseling was not always performed in a timely manner. Criteria All institutions must conduct exit counseling to inform each FDLP borrower of their rights and obligations as a borrower within 30 days of the official withdrawal or graduation date determined by the institution. Documentation of the exit counseling must be maintained in each borrower?s file. (34 C.F.R. 685.304(b)). Effect In 4 of 65 FDLP files tested, the documentation indicated that exit counseling was not performed in a timely manner. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting these instances of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution's procedures for counseling FDLP borrowers in a timely manner were not applied. Recommendation The Institution should adhere to its procedures with respect to providing borrowers with FDLP exit counseling in a timely manner and maintaining documentation in the student files. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. Following discovery of this issue in the prior audit period, the Financial Aid department had created an internal process for ensuring that automated notification is received by an assigned FA staff member to complete exit counseling upon a student separation from the college. The triggered activities were working on both campuses, but an unfortunate oversight occurred when the assigned staff member for our Chicago campus went on maternity leave. There was a brief delay when the activities were not re-assigned to a new person, causing a few students to receive the exit counseling documentation later than the required 30-day period. Upon this discovery, FA management updated the process so that a detailed exit counseling letter would be mailed out automatically by the Student Information System upon a student's status change to any 'permanent out' status. This removes the possibility of human error, ensuring that students are given the proper exit counseling notification within the required 30-day timeframe following separation from the institution.
2020-001
FINDING NO. 2021-008: CARES Act - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Higher Education Emergency Relief Fund (HEERF) Grant Program Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition The Institution did not apply HEERF II Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) Student Aid Portion funds appropriately. Criteria The CARES Act requires that institutions provide the emergency financial aid grants to students ?for expenses related to the disruption of campus operations due to Coronavirus (including eligible expenses under a student?s cost of attendance, such as food, housing, course materials, technology, health care, and childcare). Institutions may, with a student?s permission, make financial aid grants to students to satisfy account charges that were posted to the student?s account prior to December 27, 2020, as long as the student was enrolled during the period of time for which the national emergency was declared. (CARES Act Section 18004(a)(1)). Effect The Institution transferred $702,919 in HEERF II Student Aid grants from the ED G5 system to its federal funds bank account to its business bank account on January 22, 2021. The Institution?s internal control over the related compliance requirement did not satisfy the CARES Act requirements. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution misinterpreted the CARES Act requirements. Due to the Coronavirus pandemic, during the year ended March 31, 2021 the Institution had awarded a great amount of institutional scholarships to students who wanted to continue their education but stated that they would have been unable to due to financial hardship associated with the Coronavirus pandemic. Recommendation The Institution should adhere to its procedures and seek guidance if necessary to fully understand regulatory requirements with respect to the federal programs. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2021-008: CARES Act - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Higher Education Emergency Relief Fund (HEERF) Grant Program Federal Agency: U. S. Department of Education Award Year: 2020-21 Statement of Condition The Institution did not apply HEERF II Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) Student Aid Portion funds appropriately. Criteria The CARES Act requires that institutions provide the emergency financial aid grants to students ?for expenses related to the disruption of campus operations due to Coronavirus (including eligible expenses under a student?s cost of attendance, such as food, housing, course materials, technology, health care, and childcare). Institutions may, with a student?s permission, make financial aid grants to students to satisfy account charges that were posted to the student?s account prior to December 27, 2020, as long as the student was enrolled during the period of time for which the national emergency was declared. (CARES Act Section 18004(a)(1)). Effect The Institution transferred $702,919 in HEERF II Student Aid grants from the ED G5 system to its federal funds bank account to its business bank account on January 22, 2021. The Institution?s internal control over the related compliance requirement did not satisfy the CARES Act requirements. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution misinterpreted the CARES Act requirements. Due to the Coronavirus pandemic, during the year ended March 31, 2021 the Institution had awarded a great amount of institutional scholarships to students who wanted to continue their education but stated that they would have been unable to due to financial hardship associated with the Coronavirus pandemic. Recommendation The Institution should adhere to its procedures and seek guidance if necessary to fully understand regulatory requirements with respect to the federal programs. Institution Comments The Institution does not dispute this finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. The funds from the HEERF II Student Aid Portion ($702,919) grant remain segregated in an Institution money market account separate from its operating accounts. The Institution seeks to distribute these funds to eligible students and former students in compliance with the requirements of applicable law and Department of Education guidance. The Institution also intends to seek guidance from the Department in this regard prior to making any distributions. Absent approval from the Department, the Institution will return all the HEERF II funds to the Department. Even with such approval, any unused Student Aid Portion of the HEERF II funds will be returned to the Department prior to the program's end date.
FAC accepted this audit on December 29, 2020 — management decision was due June 29, 2021.
Statement of Condition Federal Direct Loan Program (FDLP) exit counseling was not performed in a timely manner for certain students. Criteria All institutions must conduct exit counseling to inform each FDLP borrower of their rights and obligations as a borrower within 30 days of the official withdrawal or graduation date determined by the institution. Documentation of the exit counseling must be maintained in each borrower?s file. (34 C.F.R. 685.304(b)). Effect In 5 of 76 FDLP files tested, the documentation indicated that exit counseling was not performed in a timely manner. In addition, documentation of loan exit counseling was missing for 2 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution's procedures for counseling FDLP borrowers in a timely manner were not always applied. Recommendation The Institution should adhere to its procedures with respect to providing borrowers with FDLP exit counseling in a timely manner and maintaining documentation in the student files. Additional Information Upon learning of this finding, the Institution mailed the exit counseling documents to Student No. 6 and 7. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition Federal Direct Loan Program (FDLP) exit counseling was not performed in a timely manner for certain students. Criteria All institutions must conduct exit counseling to inform each FDLP borrower of their rights and obligations as a borrower within 30 days of the official withdrawal or graduation date determined by the institution. Documentation of the exit counseling must be maintained in each borrower?s file. (34 C.F.R. 685.304(b)). Effect In 5 of 76 FDLP files tested, the documentation indicated that exit counseling was not performed in a timely manner. In addition, documentation of loan exit counseling was missing for 2 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution's procedures for counseling FDLP borrowers in a timely manner were not always applied. Recommendation The Institution should adhere to its procedures with respect to providing borrowers with FDLP exit counseling in a timely manner and maintaining documentation in the student files. Additional Information Upon learning of this finding, the Institution mailed the exit counseling documents to Student No. 6 and 7. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. Due to a personnel change, weekly reports for status changes were not being completed on a consistent basis, causing a delay in issuing exit counseling documentation. Management has revised the internal process so that two notifications are provided to the Financial Aid department when a student has graduated or withdrawn: 1) An email is sent from the Registrar to the department notifying of a status change; 2) A trigger has been created in the student management system that triggers a task activity immediately on the date that the status changes from active to any permanent out status. Reports will continue to be run monthly as a check & balance to verify that the appropriate exit counseling documentation is sent to all eligible students within the regulatory timeframe. The institution resolved the two missing exit counseling students at the time of the audit.
Statement of Condition The Cost of Attendance (COA) used to determine Federal Direct Loan Program eligibility was calculated incorrectly for one student. Criteria The COA (for loan purposes) and EFC must be based on like periods of time and correspond to an appropriate period of enrollment for the student. Use of the correct COA and EFC are essential for determining a student's eligibility for subsidized loan proceeds. (34 CFR 686.21(c)). Effect In 1 of 76 FDLP files tested, there was a discrepancy in the COA used to determine the students? need for Federal Subsidized Loans and the accurate data. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not follow its procedures in determining the correct COA for use in the loan certification process. Recommendation The Institution should follow its procedures to ensure that the correct COA is used in the loan certification process. Additional Information Upon learning of this finding, the Institution recalculated the COA for the student. We reviewed the revised packaging worksheet and determined that the student was underawarded in the amount of $1,285 in Federal Direct Subsidized Loan funds. The Institution reallocated the student?s Federal Unsubsidized Loan in the amount of $1,285 to a Federal Subsidized Loan. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition The Cost of Attendance (COA) used to determine Federal Direct Loan Program eligibility was calculated incorrectly for one student. Criteria The COA (for loan purposes) and EFC must be based on like periods of time and correspond to an appropriate period of enrollment for the student. Use of the correct COA and EFC are essential for determining a student's eligibility for subsidized loan proceeds. (34 CFR 686.21(c)). Effect In 1 of 76 FDLP files tested, there was a discrepancy in the COA used to determine the students? need for Federal Subsidized Loans and the accurate data. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not follow its procedures in determining the correct COA for use in the loan certification process. Recommendation The Institution should follow its procedures to ensure that the correct COA is used in the loan certification process. Additional Information Upon learning of this finding, the Institution recalculated the COA for the student. We reviewed the revised packaging worksheet and determined that the student was underawarded in the amount of $1,285 in Federal Direct Subsidized Loan funds. The Institution reallocated the student?s Federal Unsubsidized Loan in the amount of $1,285 to a Federal Subsidized Loan. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident and involved an employee erroneously utilizing an older version of a Cost of Attendance budget when determining need for a student. The staff member was trained on the proper protocol, and the finding was reviewed with the entire Financial Aid department to ensure that the current version of Cost of Attendance budgets are being used for needs analysis. The institution resolved the one student miscalculated at the time of the audit, and provided documented proof that the Federal Direct Unsubsidized Loan in the amount of $1,285 was reallocated to a Federal Direct Subsidized Loan.
Statement of Condition Verification was not completed prior to disbursement of funds in one student?s file. Criteria Federal regulations require that institutions verify certain need analysis data for students selected for verification by the U.S. Department of Education and for any student whose file contains conflicting data. Under certain conditions for the Federal Pell Grant and campus-based programs, the institution may make initial payment to the student for the first payment period while verification is being completed. If the student graduates or withdraws prior to completing verification, the institution is liable for the amount(s) disbursed (34 CFR 668.57). Effect Of 76 files tested, the file of 1 student selected for verification contained conflicting information with respect to the parent?s adjust gross income. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. The student received a Federal Pell Grant in the amount of $1,715. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not apply its procedures for obtaining and reviewing complete documentation with respect to verification. Recommendation The Institution should follow its procedures for determining a student's aid eligibility and resolving conflicting information prior to disbursement. Additional Information Upon learning of this finding, the Institution recalculated the need analysis for the student using the accurate data. We reviewed the documentation and determined that there was a decrease in the amount of $167 in Federal Pell Grant eligibility. The Institution returned $167 to the Federal Pell Grant Program. We reviewed the documentation and found it to be accurate. The student remained eligible for all other Title IV funds disbursed. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition Verification was not completed prior to disbursement of funds in one student?s file. Criteria Federal regulations require that institutions verify certain need analysis data for students selected for verification by the U.S. Department of Education and for any student whose file contains conflicting data. Under certain conditions for the Federal Pell Grant and campus-based programs, the institution may make initial payment to the student for the first payment period while verification is being completed. If the student graduates or withdraws prior to completing verification, the institution is liable for the amount(s) disbursed (34 CFR 668.57). Effect Of 76 files tested, the file of 1 student selected for verification contained conflicting information with respect to the parent?s adjust gross income. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. The student received a Federal Pell Grant in the amount of $1,715. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not apply its procedures for obtaining and reviewing complete documentation with respect to verification. Recommendation The Institution should follow its procedures for determining a student's aid eligibility and resolving conflicting information prior to disbursement. Additional Information Upon learning of this finding, the Institution recalculated the need analysis for the student using the accurate data. We reviewed the documentation and determined that there was a decrease in the amount of $167 in Federal Pell Grant eligibility. The Institution returned $167 to the Federal Pell Grant Program. We reviewed the documentation and found it to be accurate. The student remained eligible for all other Title IV funds disbursed. There are no remaining questioned costs associated with this finding. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident where the employee did not follow internal procedure in resolving conflicting information for the parent?s adjusted gross income. The staff member was trained on the proper protocol, and the finding was reviewed with the entire Financial Aid department to ensure that policies & procedures are followed as outlined to complete the verification process. The institution resolved the one student by recalculating the need analysis, and provided documented proof that the $167 reduction in Pell Grant was returned to the Federal Pell Grant Program.
2019-004
Statement of Condition Ineligible funds were not returned in a timely manner for one student. Criteria Ineligible disbursements credited to student accounts are to be returned to the appropriate Title IV program within 30 days of the later of the determination date or the date the funds were delivered to the student?s tuition account. (34 C.F.R. 668.21). Effect In 1 of 76 files tested, ineligible Title IV funds not returned within the required time frame. Therefore, this finding represents a significant deficiency in internal control. The payment associated with this finding is as follows: Title IV Program Amount Due Due Date Date Returned FDLP $ 6,627 7/31/19 8/16/19 Cause In this isolated instance of noncompliance, the Institution?s internal control did not function as designed and therefore, procedures to ensure timely returns of ineligible funds were not followed. Recommendation The Institution?s control procedures for processing ineligible funds payments should be closely followed. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition Ineligible funds were not returned in a timely manner for one student. Criteria Ineligible disbursements credited to student accounts are to be returned to the appropriate Title IV program within 30 days of the later of the determination date or the date the funds were delivered to the student?s tuition account. (34 C.F.R. 668.21). Effect In 1 of 76 files tested, ineligible Title IV funds not returned within the required time frame. Therefore, this finding represents a significant deficiency in internal control. The payment associated with this finding is as follows: Title IV Program Amount Due Due Date Date Returned FDLP $ 6,627 7/31/19 8/16/19 Cause In this isolated instance of noncompliance, the Institution?s internal control did not function as designed and therefore, procedures to ensure timely returns of ineligible funds were not followed. Recommendation The Institution?s control procedures for processing ineligible funds payments should be closely followed. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. The refund/return process was under prior management in the 2018-19 award year and did not follow proper checks & balances for this one student in returning funds within the regulatory requirement of 30 days. The institution has transitioned from a 3rd party to an in-house processing method, and the department has established internal controls for timely review of eligibility for federal student aid disbursements and returns. Management has reviewed this finding with internal staff for training, and automated reports are now generated to provide notification of status changes for the purpose of making appropriate aid adjustments.
Statement of Condition The Institution reported the enrollment status and/or status effective dates to the National Student Loan Data System (NSLDS) for certain students in error. Criteria Institutions are required to accurately report a student?s changes in enrollment status and notify NSLDS within 60 days of a student?s change in enrollment status. The Institution may utilize a Roster file (formerly called the Student Status Confirmation Report) for notification if the report will be submitted within 60 days of the status change. Accurate and timely reporting of student status changes is essential because the last day of attendance on at least a half-time basis triggers the beginning of the borrower?s grace period. Incorrect reporting of student status changes may result in federal interest subsidies being paid toward loans that should be in repayment and are no longer eligible for the subsidies. (34 CFR 685.309(b)). Effect Of 76 FDLP files tested, the enrollment status and/or status effective dates for 3 students were reported incorrectly. Additionally, the enrollment status effective dates were not updated in a timely manner for 4 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution?s procedures with respect to accurate and timely reporting to NSLDS of borrowers? enrollment status changes were not always closely followed. Recommendation The Institution should more closely follow its procedures to ensure that student enrollment status changes are reported timely and correctly to NSLDS. Additional Information Upon learning of this finding, the Institution corrected the enrollment status and/or status effective dates in NSLDS for the 3 students. We reviewed the revised documents and determined that they were accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition The Institution reported the enrollment status and/or status effective dates to the National Student Loan Data System (NSLDS) for certain students in error. Criteria Institutions are required to accurately report a student?s changes in enrollment status and notify NSLDS within 60 days of a student?s change in enrollment status. The Institution may utilize a Roster file (formerly called the Student Status Confirmation Report) for notification if the report will be submitted within 60 days of the status change. Accurate and timely reporting of student status changes is essential because the last day of attendance on at least a half-time basis triggers the beginning of the borrower?s grace period. Incorrect reporting of student status changes may result in federal interest subsidies being paid toward loans that should be in repayment and are no longer eligible for the subsidies. (34 CFR 685.309(b)). Effect Of 76 FDLP files tested, the enrollment status and/or status effective dates for 3 students were reported incorrectly. Additionally, the enrollment status effective dates were not updated in a timely manner for 4 students. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution?s procedures with respect to accurate and timely reporting to NSLDS of borrowers? enrollment status changes were not always closely followed. Recommendation The Institution should more closely follow its procedures to ensure that student enrollment status changes are reported timely and correctly to NSLDS. Additional Information Upon learning of this finding, the Institution corrected the enrollment status and/or status effective dates in NSLDS for the 3 students. We reviewed the revised documents and determined that they were accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. Under prior management, Columbia College Hollywood was utilizing a third party servicer for submitting Roster files (formerly Student Status Confirmation Reports). It was discovered during the audit that select files were not reported accurately with the third party servicer, causing incorrect data to be submitted or late reporting to occur. The department is now under new management and has transitioned away from a third party servicer to an in-house process. Our Registrar downloads the Roster file every 60 days and submits current student status per statutory regulation. Additionally, a trigger system was created in our student management system that alerts staff when a student has withdrawn or been dismissed. Staff on each campus is responsible for updating NSLDS at the time of separation so that the grace period is more accurate to the time of separation. This finding was reviewed with internal staff for training purposes, and corrected information was submitted to NSLDS with proof provided for the 3 affected students.
Statement of Condition One student was underawarded in Federal Pell Grant funds. Criteria An institution is required to pro-rate Federal Pell award amounts, perform need analysis calculations, and review prior aid history to ensure that students are appropriately awarded. (34 CFR 690.79.) Effect In 1 of 50 Federal Pell Grant files tested, the student was underawarded in 2019-20 Federal Pell Grant funds in the amount of $757. The student was underpaid due to a change in enrollment status. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance of noncompliance, internal control did not function as designed and the Institution did not follow its procedures with respect to the awarding of Title IV funds. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Additional Information Upon learning of this finding, the Institution credited $757 to the student with institutional funds and since the student did not have an outstanding tuition account balance, the Institution returned $757 to the student?s Federal Direct Unsubsidized Loan. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition One student was underawarded in Federal Pell Grant funds. Criteria An institution is required to pro-rate Federal Pell award amounts, perform need analysis calculations, and review prior aid history to ensure that students are appropriately awarded. (34 CFR 690.79.) Effect In 1 of 50 Federal Pell Grant files tested, the student was underawarded in 2019-20 Federal Pell Grant funds in the amount of $757. The student was underpaid due to a change in enrollment status. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In this isolated instance of noncompliance, internal control did not function as designed and the Institution did not follow its procedures with respect to the awarding of Title IV funds. Recommendation The Institution should closely follow its procedures to ensure that students are appropriately awarded. Additional Information Upon learning of this finding, the Institution credited $757 to the student with institutional funds and since the student did not have an outstanding tuition account balance, the Institution returned $757 to the student?s Federal Direct Unsubsidized Loan. We reviewed the documentation and found it to be accurate. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. This was an isolated incident resulting from a staff member not following up on aid eligibility as a result of a change in enrollment status. Personnel was trained on the proper protocol, and the finding was reviewed with the entire Financial Aid department to ensure that enrollment changes are reviewed at proper intervals and adjustments made on a consistent basis. The institution credited $757 in institutional funds to the student to resolve the issue at the time of the audit, and provided documented proof that the funds were returned to the student?s Federal Direct Unsubsidized Loan since there was no outstanding balance on the student tuition account.
Statement of Condition The Institution?s 2018-19 Fiscal Operations Report and Application to Participate (FISAP) was not submitted for the Chicago additional location campus. Criteria The FISAP is a report that institutions submit annually for the award year ending during the institution?s fiscal year that accounts for program activity during that period and to apply for future funding in the campus-based programs (FSEOG, Federal Perkins Loans, and Federal Work Study). Institutions must submit the FISAP on or before the deadline date published annually in the Federal Register. The Institution?s Hollywood and Chicago campuses merged legally and with U.S.D.E. approval in March 2018. Each campus was required to submit a FISAP report for the award years ended June 30, 2019 and 2018. Effect During our tests of Federal reporting requirements, we noted that the 2018-19 FISAP was not submitted for the Chicago additional location campus. Cause The Institution inadvertently did not submit the 2018-19 FISAP for the Chicago additional location campus. Recommendation The Institution should follow its procedures to ensure that all reports associated with the Title IV programs are submitted accurately and in a timely manner. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴Statement of Condition The Institution?s 2018-19 Fiscal Operations Report and Application to Participate (FISAP) was not submitted for the Chicago additional location campus. Criteria The FISAP is a report that institutions submit annually for the award year ending during the institution?s fiscal year that accounts for program activity during that period and to apply for future funding in the campus-based programs (FSEOG, Federal Perkins Loans, and Federal Work Study). Institutions must submit the FISAP on or before the deadline date published annually in the Federal Register. The Institution?s Hollywood and Chicago campuses merged legally and with U.S.D.E. approval in March 2018. Each campus was required to submit a FISAP report for the award years ended June 30, 2019 and 2018. Effect During our tests of Federal reporting requirements, we noted that the 2018-19 FISAP was not submitted for the Chicago additional location campus. Cause The Institution inadvertently did not submit the 2018-19 FISAP for the Chicago additional location campus. Recommendation The Institution should follow its procedures to ensure that all reports associated with the Title IV programs are submitted accurately and in a timely manner. Institution Comments The Institution does not dispute the finding. The Institution has procedures in place to ensure full compliance as detailed in the Corrective Action Plan.
The institution does not dispute this finding. Columbia College Hollywood legally merged with Flashpoint Chicago with U.S.D.O.E. approval in March 2018. At the time, the Financial Aid department was under prior management and working with a third party servicer when submitting the annual FISAP report. Prior management erroneously assumed that a single FISAP for Columbia College Hollywood was all that was required for the 2018-19 award year, and thus did not complete a separate FISAP submission for Flashpoint Chicago, nor were students on the Chicago campus included on the 2018-19 FISAP grid. The college is now under new management in the Financial Aid department, and all operations and processes are completed in-house. The data elements for both campuses is now submitted on a single FISAP submission as required by U.S.D.O.E. regulation. This finding was reviewed with internal staff, and senior personnel are tracking all reports associated with the Title IV programs to ensure accurate and timely submission.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FINDING NO. 2019-001 (Repeat Finding) Statement of Condition Company personnel did not consistently perform timely, accurate and complete reconciliations and analysis of subsidiary ledgers. The most significant areas pertained to accounts receivable, fixed assets, deferred tuition and accrued liabilities. Numerous post-closing adjustments were necessary to properly state the financial statements. Criteria Management is responsible for performing timely, accurate and complete reconciliations and analysis of subsidiary ledgers. Internal controls in place should be adequate to prevent, or detect and correct misstatements in the financial statements on a timely basis. Effect The lack of timely reconciliations creates the risk that errors or discrepancies will go unnoticed for extended periods of time. It also creates the opportunity for fraud if there is inadequate oversight of the general ledger accounts on a timely basis. Cause Timely, accurate and complete reconciliations were not performed due to lack of month/year end closing calendar. Recommendation Management should ensure that timely, accurate and complete reconciliations and analysis of subsidiary ledgers are performed. Institution Comments Management agrees with the findings. In October 2019, the Institution replaced the Chief Financial Officer originally responsible for the books of record as of March 31, 2019. In October 2019, the Institution contracted an Interim Chief Financial Officer who has been implementing new accounting and financial reporting procedures, including but not limited to, establishing a documented accounting and financial reporting closing process. The documented process includes daily, weekly, monthly and quarterly procedures to be performed by specific staff with required sign and date completion by both the person responsible and reviewer. Additionally, the documented process defines required monthly reconciliations to be performed with date and signatures of performer and reviewer. Reconciling items are expected to be resolved in the subsequent month where immaterial to the current month reporting. The Interim Chief Financial Officer has been training staff members in accounting and workpaper techniques for proper reconciliation documentation. The Interim Chief Financial Officer performed the due diligence required to get the March 31, 2019 books of record properly stated and supported to have accurate financial statements and footnotes as of March 31, 2019.
Show full finding ▾Hide full finding ▴FINDING NO. 2019-001 (Repeat Finding) Statement of Condition Company personnel did not consistently perform timely, accurate and complete reconciliations and analysis of subsidiary ledgers. The most significant areas pertained to accounts receivable, fixed assets, deferred tuition and accrued liabilities. Numerous post-closing adjustments were necessary to properly state the financial statements. Criteria Management is responsible for performing timely, accurate and complete reconciliations and analysis of subsidiary ledgers. Internal controls in place should be adequate to prevent, or detect and correct misstatements in the financial statements on a timely basis. Effect The lack of timely reconciliations creates the risk that errors or discrepancies will go unnoticed for extended periods of time. It also creates the opportunity for fraud if there is inadequate oversight of the general ledger accounts on a timely basis. Cause Timely, accurate and complete reconciliations were not performed due to lack of month/year end closing calendar. Recommendation Management should ensure that timely, accurate and complete reconciliations and analysis of subsidiary ledgers are performed. Institution Comments Management agrees with the findings. In October 2019, the Institution replaced the Chief Financial Officer originally responsible for the books of record as of March 31, 2019. In October 2019, the Institution contracted an Interim Chief Financial Officer who has been implementing new accounting and financial reporting procedures, including but not limited to, establishing a documented accounting and financial reporting closing process. The documented process includes daily, weekly, monthly and quarterly procedures to be performed by specific staff with required sign and date completion by both the person responsible and reviewer. Additionally, the documented process defines required monthly reconciliations to be performed with date and signatures of performer and reviewer. Reconciling items are expected to be resolved in the subsequent month where immaterial to the current month reporting. The Interim Chief Financial Officer has been training staff members in accounting and workpaper techniques for proper reconciliation documentation. The Interim Chief Financial Officer performed the due diligence required to get the March 31, 2019 books of record properly stated and supported to have accurate financial statements and footnotes as of March 31, 2019.
In October 2019, the Institution replaced the Chief Financial Officer originally responsible for the books of record as of March 31, 2019. In October 2019, the Institution contracted an Interim Chief Financial Officer who has been implementing new accounting and financial reporting procedures, including but not limited to, establishing a documented accounting and financial reporting closing process. The documented process includes daily, weekly, monthly and quarterly procedures to be performed by specific staff with required sign and date completion by both the person responsible and reviewer. Additionally, the documented process defines required monthly reconciliations to be performed with date and signatures of performer and reviewer. Reconciling items are expected to be resolved in the subsequent month where immaterial to the current month reporting. The Interim Chief Financial Officer has been training staff members in accounting and workpaper techniques for proper reconciliation documentation. The Interim Chief Financial Officer performed the due diligence required to get the March 31, 2019 books of record properly stated and supported to have accurate financial statements and footnotes as of March 31, 2019.
2018-001
FINDING NO. 2019-002: Common Origination and Disbursement system (COD) Discrepancy - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition Reconciliation of FDLP disbursement dates in the Common Origination and Disbursement system (COD) with the Institution?s records was not always performed. Criteria Reconciliation of student disbursement data and/or transmission adjustments of rejected records are required to be submitted to COD within 15 days of payment or of the Institution becoming aware of the need to make an adjustment. Additionally, FDLP disbursement dates in COD are required to match the Institution?s records (34 CFR 668.164(a) and 34 CFR 690.83). Effect Of 150 FDLP records tested, 50 students? Federal Direct Loan Program disbursement dates in COD differed from the Institution?s records. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution did not always complete reconciliation of FDLP disbursement dates in COD with the Institution?s records. Recommendation The Institution should adhere to its policies of reconciliation of FDLP disbursement dates in COD with the Institution?s records. Additional Information Upon learning of this finding, the Institution corrected COD to reflect students? ledger disbursement dates. We reviewed the documentation and found it to be accurate. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2019-002: Common Origination and Disbursement system (COD) Discrepancy - Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition Reconciliation of FDLP disbursement dates in the Common Origination and Disbursement system (COD) with the Institution?s records was not always performed. Criteria Reconciliation of student disbursement data and/or transmission adjustments of rejected records are required to be submitted to COD within 15 days of payment or of the Institution becoming aware of the need to make an adjustment. Additionally, FDLP disbursement dates in COD are required to match the Institution?s records (34 CFR 668.164(a) and 34 CFR 690.83). Effect Of 150 FDLP records tested, 50 students? Federal Direct Loan Program disbursement dates in COD differed from the Institution?s records. Therefore, this finding represents a significant deficiency in internal control. Cause The Institution did not always complete reconciliation of FDLP disbursement dates in COD with the Institution?s records. Recommendation The Institution should adhere to its policies of reconciliation of FDLP disbursement dates in COD with the Institution?s records. Additional Information Upon learning of this finding, the Institution corrected COD to reflect students? ledger disbursement dates. We reviewed the documentation and found it to be accurate. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
As stated within the Independent Auditors? Report, all discrepancies cited have been corrected. The College will continue to adhere to its policies and procedures to ensure that all future disbursements posted to the student ledgers will be matched to the COD disbursement date. As an additional layer of review, the CCH financial aid team will complete monthly audits to validate that the disbursement dates in CampusVue align with COD.
FINDING NO. 2019-003: Missing Proof of High School Graduation Transcript ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Years: 2017-18 and 2018-19 Statement of Condition One student file did not contain documentation confirming the student?s high school graduation or GED. Criteria The Institution?s policy is only to accept for admission applicants who have graduated from high school or possess a GED. Documentation is required and is maintained in the student file. (34 CFR 600.2). Effect In 1 of the 150 files tested, the file did not contain evidence of a high school diploma or GED. The student received a Federal Pell Grant in the amount of $6,095, a Federal Supplemental Educational Opportunity Grant in the amount of $200, and a Federal Direct Loan in the amount of $16,120. Total questioned costs are $22,415. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution's procedures for ensuring that all documents are maintained in the student's file and for resolving conflicting information were not followed. Recommendation The Institution's procedures for ensuring document maintenance and review should be closely followed. Additional Information Upon learning of this finding, the Institution obtained documentation of the student?s high school graduation transcript. We reviewed the documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2019-003: Missing Proof of High School Graduation Transcript ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Years: 2017-18 and 2018-19 Statement of Condition One student file did not contain documentation confirming the student?s high school graduation or GED. Criteria The Institution?s policy is only to accept for admission applicants who have graduated from high school or possess a GED. Documentation is required and is maintained in the student file. (34 CFR 600.2). Effect In 1 of the 150 files tested, the file did not contain evidence of a high school diploma or GED. The student received a Federal Pell Grant in the amount of $6,095, a Federal Supplemental Educational Opportunity Grant in the amount of $200, and a Federal Direct Loan in the amount of $16,120. Total questioned costs are $22,415. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution's procedures for ensuring that all documents are maintained in the student's file and for resolving conflicting information were not followed. Recommendation The Institution's procedures for ensuring document maintenance and review should be closely followed. Additional Information Upon learning of this finding, the Institution obtained documentation of the student?s high school graduation transcript. We reviewed the documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
CCH will adhere to its procedure related to document maintenance and review to ensure all proof of graduation records are properly stored and reviewed prior to disbursement of aid.
FINDING NO. 2019-004: Incomplete Verification ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition Verification was not completed prior to disbursement of funds in one student?s file. Criteria Federal regulations require that institutions verify certain need analysis data for students selected for verification by the U.S. Department of Education and for any student whose file contains conflicting data. Under certain conditions for the Federal Pell Grant and campus-based programs, the institution may make initial payment to the student for the first payment period while verification is being completed. If the student graduates or withdraws prior to completing verification, the institution is liable for the amount(s) disbursed (34 CFR 668.57). Effect Of 150 files tested, the file of 1 student selected for verification was missing the parent?s tax transcript. The student received a Federal Pell Grant in the amount of $4,288, FSEOG in the amount of $125 and a Federal Direct Subsidized Loan in the amount of $330 in the 2018-19 award year. Total net aid received was $4,743. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not apply its procedures for obtaining and reviewing complete documentation with respect to verification. Recommendation The Institution should follow its procedures for determining a student's aid eligibility and resolving conflicting information prior to disbursement. Additional Information Upon learning of this finding, the Institution obtained the parent?s tax transcript and recalculated the need analysis using the correct data. We reviewed a copy of the recalculation and determined that there was a decrease in Federal Pell Grant eligibility in the amount of $750. The Institution returned the funds in the amount of $750 to the Federal Pell Grant Program. We reviewed the repayment documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2019-004: Incomplete Verification ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition Verification was not completed prior to disbursement of funds in one student?s file. Criteria Federal regulations require that institutions verify certain need analysis data for students selected for verification by the U.S. Department of Education and for any student whose file contains conflicting data. Under certain conditions for the Federal Pell Grant and campus-based programs, the institution may make initial payment to the student for the first payment period while verification is being completed. If the student graduates or withdraws prior to completing verification, the institution is liable for the amount(s) disbursed (34 CFR 668.57). Effect Of 150 files tested, the file of 1 student selected for verification was missing the parent?s tax transcript. The student received a Federal Pell Grant in the amount of $4,288, FSEOG in the amount of $125 and a Federal Direct Subsidized Loan in the amount of $330 in the 2018-19 award year. Total net aid received was $4,743. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause In these instances of noncompliance, the Institution?s internal control did not function as designed and therefore, the Institution did not apply its procedures for obtaining and reviewing complete documentation with respect to verification. Recommendation The Institution should follow its procedures for determining a student's aid eligibility and resolving conflicting information prior to disbursement. Additional Information Upon learning of this finding, the Institution obtained the parent?s tax transcript and recalculated the need analysis using the correct data. We reviewed a copy of the recalculation and determined that there was a decrease in Federal Pell Grant eligibility in the amount of $750. The Institution returned the funds in the amount of $750 to the Federal Pell Grant Program. We reviewed the repayment documentation and found it to be accurate. There are no remaining questioned costs associated with this finding. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
CCH will follow its procedures for determining student aid eligibility and will resolve all conflicting information within the student file prior to disbursement.
FINDING NO. 2019-005: Gramm-Leach Bliley Act Policy ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition The Institution did not comply with provisions contained in the Gramm-Leach-Bliley Act (GLBA). Criteria The GLBA (16 CFR 314.4 (b)) includes specific compliance requirements designed to enhance the security of student information maintained electronically by institutions of higher education, as well as third party servicers and other vendors who may require sensitive student information to perform their duties. The compliance requirements include the designation of an individual to coordinate the information security program, periodic risk assessment in three specific areas, and designing and documenting safeguards for identified risks. Effect The Institution was unable to demonstrate compliance with the GLBA, specifically identifying an individual responsible for coordinating the information security program or performing a risk assessment during the audit period that addressed the three required areas described in 16 CFR 314.4 (b). The three areas are: Employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and, detecting, preventing and responding to attacks, intrusions, or other systems failures. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause While the Institution has in place information systems security protocols and personnel, the Institution had not implemented the specific requirements contained in the GLBA. Recommendation The Institution needs to design and implement a periodic risk assessment process in the three areas described in 16 CFR 314.4 (b), create and document safeguards for identified risks, and designate an individual responsible for coordinating the Institution?s information security program. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
Show full finding ▾Hide full finding ▴FINDING NO. 2019-005: Gramm-Leach Bliley Act Policy ? Significant Deficiency in Internal Control and Instance of Non-Compliance Federal Program: Student Financial Assistance Cluster Federal Agency: U. S. Department of Education Award Year: 2018-19 Statement of Condition The Institution did not comply with provisions contained in the Gramm-Leach-Bliley Act (GLBA). Criteria The GLBA (16 CFR 314.4 (b)) includes specific compliance requirements designed to enhance the security of student information maintained electronically by institutions of higher education, as well as third party servicers and other vendors who may require sensitive student information to perform their duties. The compliance requirements include the designation of an individual to coordinate the information security program, periodic risk assessment in three specific areas, and designing and documenting safeguards for identified risks. Effect The Institution was unable to demonstrate compliance with the GLBA, specifically identifying an individual responsible for coordinating the information security program or performing a risk assessment during the audit period that addressed the three required areas described in 16 CFR 314.4 (b). The three areas are: Employee training and management; information systems, including network and software design, as well as information processing, storage, transmission and disposal; and, detecting, preventing and responding to attacks, intrusions, or other systems failures. The Institution?s internal control over the related compliance requirement did not function as designed and was not effective in detecting this instance of non-compliance. Therefore, this finding represents a significant deficiency in internal control. Cause While the Institution has in place information systems security protocols and personnel, the Institution had not implemented the specific requirements contained in the GLBA. Recommendation The Institution needs to design and implement a periodic risk assessment process in the three areas described in 16 CFR 314.4 (b), create and document safeguards for identified risks, and designate an individual responsible for coordinating the Institution?s information security program. Institution Comments The Institution concurs with the finding and has procedures in place to ensure compliance with the requirements. Details are included in the Corrective Action Plan.
CCH will revisit 16 CFR 314.4 (b) to become more familiar with the Gramm-Leach- Bliley Act requirements outlined by ED. Upon completion of the review, the College will design and implement a periodic risk assessment process in the three areas described within the GLBA, create and document safeguards for identified risks, and designate an individual responsible for coordinating the College's information security program.
FAC accepted this audit on May 30, 2019 — management decision was due November 30, 2019.
GSA_MIGRATION
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2017-005
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FAC accepted this audit on May 30, 2018 — management decision was due November 30, 2018.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on May 14, 2017 — management decision was due November 14, 2017.
GSA_MIGRATION
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