Audit 1222

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-001 – Return of Title IV Funds – Enrollment Reporting Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60 day requirement. Criteria CFR section 685.309 and 690.83(b)(2) requires the College to notify the NSLDS within 30 days of a change in student status or include the change in status in a response to an enrollment reporting roster within 60 days of the student’s date of determination of withdrawal. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that enrollment status changes are reported timely. Questioned Costs There were no questioned costs related to testing of enrollment reporting. Cause Certain reports submitted by the College to the NSLDS contained formatting errors that needed to be cleared by the College before they could be processed. The College did not clear the errors timely and therefore missed the 60-day requirement to report students’ status changes at the campus and program level. Prevalence Frequent. Eight out of ten students selected for testing. Effect Failure to report status changes timely is noncompliance with Federal regulation and could result in loss of future funding. Recommendation We recommend the College implement monitoring procedures which will promptly notify the financial aid office of any errors in submission of the enrollment data to the National Student Clearinghouse. A system of monitoring procedures and/or controls will ensure the College is reporting any status changes to the lender in a timely manner and resolving any errors in submissions. The College should implement a review process to ensure all submission errors are addressed by the financial aid office in a timely manner. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-005 – Program Eligibility – Clock to Credit Hour Conversion Repeat Finding: No Federal Program Title – U.S. Department of Education Student Financial Assistance Cluster Federal Pell Grant Program: 84.063 Federal Direct Student Loans: 84.268 Federal Supplemental Educational Opportunity Grants 84.007 Federal Award Year 2022-2023 Condition The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Criteria Under Uniform Grant Guidance (34 CFR 688.8) if the institution offers an undergraduate educational program in credit hours in what is considered a non-degree program, the appropriate conversion formula must be applied unless: • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program. The formula will determine if, after the conversion, the program includes the minimum number of credit hours to qualify as an eligible program for financial aid purposes. The formula also determines the number of Title IV credit hours associated with each class that an institution can use to determine a student’s enrollment status during the program. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that the appropriate clock to credit hour conversion formula is applied to applicable programs. Questioned Costs Unknown Cause The College failed to identify certain applicable requirements and therefore did not perform this calculation. Prevalence Frequent. Five out of five programs selected for testing. Effect Lack of proper clock to credit hour conversions could result in the over awarding of financial aid to students enrolled in certain programs. Recommendation We recommend the College review current processes, policies and procedures to ensure that clock to credit hour conversion formulas are being properly applied and documentation is being retained by the College. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-002 – Cash Management – Subrecipient Payments Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of two subrecipient payments tested (50%), the College did not submit payment within 30 days after receipt of the billing from the subrecipient. Criteria Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. The College made payment to the subrecipient 105 days after receipt of the billing from the subrecipient. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Questioned Costs There were no questioned costs related to testing of subrecipient payments. Cause To ensure the College is fully monitoring both programmatic activities and financial compliance with Uniform Guidance cost principles of its subrecipients, the College’s internal control procedure requires signatures from the Principal Investigator (PI), Director of Resource Development, and the Manager of Grants Accounting and Compliance. Delays in the internal approval process caused the delay in payment of the sampled invoice. Prevalence Frequent. One out of two payments selected for testing. Effect Without proper program cash management policies and procedures, late subrecipient payments could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that payments to subrecipients minimize the time elapsing between transfer of federal funds from the pass-through entity to the subrecipient. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA) Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 1 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $ 75,000 $ 75,000 $ 0 $ 0 $ 0 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely. Questioned Costs There were no questioned costs related to reporting. Cause The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement. Prevalence Frequent. One out of one subawards selected for testing. Effect Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.

Finding 2023-004 – Internal Controls for Subrecipient Monitoring Repeat Finding: No Federal Program Title – U.S. Department of Defense Cybersecurity Core Curriculum 12.905 Condition The College did not have sufficient documentation that internal controls were in place and operating effectively over risk assessment procedures required by the subrecipient monitoring compliance requirement. Although the College was able to provide a timeline noting a risk assessment took place and ongoing monitoring was occurring, there was no formal documentation of the risk assessment. Criteria Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures in place to ensure that reviews are formally documented over subrecipient monitoring. Questioned Costs There were no questioned costs related to reporting. Cause The National Security Agency pre-selected the subrecipient college for this grant. As a result, the College did not fully utilize its subrecipient monitoring tool to document its rigorous subrecipient risk assessment and monitoring process. Prevalence Frequent. One out of one subawards selected for testing. Effect Lack of properly documented evidence of subrecipient monitoring policies and procedures could result in the loss of future funding. Recommendation We recommend the College review current processes, policies and procedures to ensure that subrecipient monitoring policies and procedures are properly documented for each subaward. Views of responsible officials We agree with this finding. See corrective action plan.