EIN: 956006659
UEI: WFRGD7JMPAD3
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 16, 2026. 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 July 16, 2026 (37 days ago).
What is a management decision? →Criteria 34 CFR 668.22(a) and 34 CFR 668.22(e) When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The amount of Title IV assistance that is earned by the student is calculated by determining the percentage of aid earned by the student and applying the percentage to the total amount of Title IV assistance that was disbursed and that could have been disbursed to the student. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, or on his or her behalf, as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. 34 CFR 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance– During testing over Return of Title IV requirements, the following exceptions were noted: The District inaccurately calculated the Return of Title IV funds for 3 out of the 60 students due to an error in counting the calendar days completed and the total calendar days in the period. Of the 3 errors noted, 1 student received a post-withdrawal disbursement when in fact, there should have been a return of funds back to ED. The District did not return the institution’s portion of the required return in a timely manner for 2 out of the 60 students. Questioned Costs There are no questioned costs associated with the condition identified. Context There were 997 Return of Title IV calculations performed during the year ended June 30, 2025. Effect The District is not in compliance with the Federal Return of Title IV requirements described in the OMB Compliance Supplement. Cause The District’s internal controls were not sufficient to ensure that the Return of Title IV funds were calculated timely and accurately, and returned in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should strengthen internal controls over the review of Return of Title IV calculations to ensure that calculations are accurate, and funds are returned in a timely manner. Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement.
Show full finding ▾Hide full finding ▴Criteria 34 CFR 668.22(a) and 34 CFR 668.22(e) When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. The amount of Title IV assistance that is earned by the student is calculated by determining the percentage of aid earned by the student and applying the percentage to the total amount of Title IV assistance that was disbursed and that could have been disbursed to the student. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, or on his or her behalf, as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. 34 CFR 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance– During testing over Return of Title IV requirements, the following exceptions were noted: The District inaccurately calculated the Return of Title IV funds for 3 out of the 60 students due to an error in counting the calendar days completed and the total calendar days in the period. Of the 3 errors noted, 1 student received a post-withdrawal disbursement when in fact, there should have been a return of funds back to ED. The District did not return the institution’s portion of the required return in a timely manner for 2 out of the 60 students. Questioned Costs There are no questioned costs associated with the condition identified. Context There were 997 Return of Title IV calculations performed during the year ended June 30, 2025. Effect The District is not in compliance with the Federal Return of Title IV requirements described in the OMB Compliance Supplement. Cause The District’s internal controls were not sufficient to ensure that the Return of Title IV funds were calculated timely and accurately, and returned in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should strengthen internal controls over the review of Return of Title IV calculations to ensure that calculations are accurate, and funds are returned in a timely manner. Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement.
Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement. Implementation Date: September 2025
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
Program Name: Small Business Administration (SBA) Federal Financial Assistance Listing Number: 59.037 Federal Agency: Small Business Administration Direct funded from the Small Business Administration Criteria or Specific Requirements The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to $30,000. Condition Material weakness in Internal Control over Compliance - required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Questioned Costs There are no questioned costs associated with this finding. Context/Sampling All subaward obligations were selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 13 $1,350,000 Not Reported 13 $1,350,000 Not Timely 13 $1,350,000 Obligation Incorrect 13 $1,350,000 Missing Key Elements 13 $1,350,000 Effect Subaward obligations were not reported in the FSRS and therefore not included on the FFATA's website for public information disclosure. Cause The District did not have adequate internal controls to ensure subaward information was submitted in accordance with the FFATA. Repeat finding (Yes or No) No Recommendation The District should implement internal controls to ensure sub award information is submitted in accordance with the FAATA requirements.
Show full finding ▾Hide full finding ▴Program Name: Small Business Administration (SBA) Federal Financial Assistance Listing Number: 59.037 Federal Agency: Small Business Administration Direct funded from the Small Business Administration Criteria or Specific Requirements The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to $30,000. Condition Material weakness in Internal Control over Compliance - required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Questioned Costs There are no questioned costs associated with this finding. Context/Sampling All subaward obligations were selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 13 $1,350,000 Not Reported 13 $1,350,000 Not Timely 13 $1,350,000 Obligation Incorrect 13 $1,350,000 Missing Key Elements 13 $1,350,000 Effect Subaward obligations were not reported in the FSRS and therefore not included on the FFATA's website for public information disclosure. Cause The District did not have adequate internal controls to ensure subaward information was submitted in accordance with the FFATA. Repeat finding (Yes or No) No Recommendation The District should implement internal controls to ensure sub award information is submitted in accordance with the FAATA requirements.
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Management concurs and will implement internal controls to ensure subaward information in accordance with the FFATA requirements. As of December 8, 2023, the District has submitted the required subaward information for past subawards. Going forward, the District will implement internal controls to ensure subaward information is submitted within the timeframe specified in the FFATA requirements. Implementation Date: December 8, 2023
FAC accepted this audit on March 1, 2022 — management decision was due September 1, 2022.
Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student's control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance ? During testing over Return to Title IV requirements, the following deficiencies were noted: - 9 of 60 Return to Title IV calculations were not done within the 45-day requirement. - 2 of 23 unofficial withdrawal Return to Title IV calculations had a withdrawal determination date outside of the required 30 days following the term end. Questioned Costs There are no questioned costs associated with the condition identified. Context The District did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. Effect Without proper monitoring of accuracy and student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding: (Yes or No) No. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes. In addition, controls should be established to ensure all return to Title IV calculations for unofficial withdrawals are performed within 30 days following the end of each term.
Show full finding ▾Hide full finding ▴Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student's control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance ? During testing over Return to Title IV requirements, the following deficiencies were noted: - 9 of 60 Return to Title IV calculations were not done within the 45-day requirement. - 2 of 23 unofficial withdrawal Return to Title IV calculations had a withdrawal determination date outside of the required 30 days following the term end. Questioned Costs There are no questioned costs associated with the condition identified. Context The District did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. Effect Without proper monitoring of accuracy and student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding: (Yes or No) No. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes. In addition, controls should be established to ensure all return to Title IV calculations for unofficial withdrawals are performed within 30 days following the end of each term.
Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid Department continues to adhere to their recent 2021-2022 R2T4 Policy and Procedures found on pages 1-6 of the Return of Title IV (R2T4) and Overpayment manual. Moreover, the Financial Aid Department has continued to work closely with US Department of Education Program Compliance Review Specialists regarding previous R2T4 findings. Throughout the last 14 months, and as recent as December 2021, the Financial Aid Team has participated in deep discussions and deeper reviews of the R2T4 procedures with the Finance Department. We will ensure timely review and reporting of withdraws in accordance with requirements.
Special Tests and Provisions - Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, 1 of 60 student enrollment statuses, changes, and program information were never reported to NSLDS due to an error in uploading the student?s information. Questioned Costs There are no questioned costs associated with the condition identified. Context The District disbursed financial aid to approximately 6,400 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not have controls in place to ensure that errors in the NSLDS reporting process are corrected and uploaded properly. Repeat Finding: (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Show full finding ▾Hide full finding ▴Special Tests and Provisions - Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, 1 of 60 student enrollment statuses, changes, and program information were never reported to NSLDS due to an error in uploading the student?s information. Questioned Costs There are no questioned costs associated with the condition identified. Context The District disbursed financial aid to approximately 6,400 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not have controls in place to ensure that errors in the NSLDS reporting process are corrected and uploaded properly. Repeat Finding: (Yes or No) No. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Views of Responsible Officials and Corrective Action Plan We concur. The Director, Financial Aid and Veteran Services in conjunction with the Director, Admissions and Records, the Admissions and Records Data Software Specialist, the Director of IT and Institutional Researcher, following the established reporting calendar, will review enrollment reporting procedures and control procedures to ensure timely and accurate reporting to NSLDS from the National Student Clearinghouse. We will confirm completion and verification of uploads.
Reporting Program Name: Covid-19: Higher Education Emergency Relief Funds, Student Aid Portion and COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Agency: U.S Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion and Institutional Aid Portion award to publicly post certain information on their website for each calendar quarter no later than ten days after the end of each calendar quarter. Condition Significant Deficiency in Internal Control Over Compliance - The institutional portion report for the quarter ended September 30, 2020 was made publicly available 30 days after quarter end. In addition, the student portion report was made available fifteen days after quarter end. Therefore, the District did not meet the timeliness requirement. Questioned Costs There are no questioned costs associated with the condition identified. Context The District is required to report quarterly the colleges activities and student grant metrics within ten days from the calendar quarter end. Based on a sample of reports tested , it was noted that one student report and one institutional report were not submitted in a timely manner. Effect The College?s September 30, 2020 quarter end report for the institutional portion was posted 20 days late and the student portion was posted five days late. Cause There was a lack of oversight in the quarterly reporting requirement for the student aid portion and institutional portion reporting. Repeat Finding: (Yes or No) No. Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met.
Show full finding ▾Hide full finding ▴Reporting Program Name: Covid-19: Higher Education Emergency Relief Funds, Student Aid Portion and COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Numbers: 84.425E and 84.425F Federal Agency: U.S Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion and Institutional Aid Portion award to publicly post certain information on their website for each calendar quarter no later than ten days after the end of each calendar quarter. Condition Significant Deficiency in Internal Control Over Compliance - The institutional portion report for the quarter ended September 30, 2020 was made publicly available 30 days after quarter end. In addition, the student portion report was made available fifteen days after quarter end. Therefore, the District did not meet the timeliness requirement. Questioned Costs There are no questioned costs associated with the condition identified. Context The District is required to report quarterly the colleges activities and student grant metrics within ten days from the calendar quarter end. Based on a sample of reports tested , it was noted that one student report and one institutional report were not submitted in a timely manner. Effect The College?s September 30, 2020 quarter end report for the institutional portion was posted 20 days late and the student portion was posted five days late. Cause There was a lack of oversight in the quarterly reporting requirement for the student aid portion and institutional portion reporting. Repeat Finding: (Yes or No) No. Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met.
View of Responsible Officials and Corrective Action Plan We concur. The Director of Finance will ensure timely and accurate submission of reports.
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