Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The OMB Compliance Supplement states that the total number of calendar days in an enrollment
period includes all days within the period, excluding scheduled breaks of at least five consecutive days. Condition. For the Winter 2023 semester, a break of 5 days (excluding weekends) was being subtracted
instead of 9 days (including weekends) from the total days in the term, which resulted in the calculation being
incorrect for all students who had returns in the Winter 2023 semester. Cause. The College does not have a review process in place for reporting the number of days used in the
enrollment period. Effect. As a result of this condition, Return of Title IV calculations were incorrect for 21 students for the Winter
2023 semester, resulting in $4,265 in excess funds returned to the U.S. Department of Education. It is our
understanding that on July 26, 2023, the College repaid the 21 students affected by this calculation error. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the 21 students impacted by the calculation error in the Winter 2023 Semester. However, we recommend that
the College implement a review process to ensure that the R2T4 calculation is being reviewed by a second
individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action
Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special
Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial
institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of multi‐factor
authentication for anyone accessing customer information on the institution's system, conducting a periodic
inventory of data that notes where it is collected, store, or transmitted, encrypting customer information on the
institution's system and when it's in transit, and the assessment of apps developed by the institution. Cause. The College does not have a review process in place for ensuring all safeguard policies are met in
accordance with the Gramm Leach Bliley Act. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply
with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is
possessed by the College. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach
Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance
(Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers
84.007, 84.033, 84.063, and 84.268; Award Numbers P007A222054, P033A222054, P063P221646, and
P268K231646. Criteria. Recipients of Title IV grants/loans who have withdrawn from an institution earn a certain percentage
of aid based on their percentage of the semester completed. Condition. Instead of earning additional aid due to the Return of Title IV calculation error, one of the twenty
one students who were affected saw a reduction due to a transposition/rounding error that was missed in the
original calculation. Cause. The College does not have a formal review process where a second individual looks over the Return of
Title IV calculation to ensure errors are caught before the returns are processed.Effect. As a result of this condition, input errors for the Return of Title IV calculations can make it through the
process without being discovered. It is our understanding that on July 26, 2023, the College corrected the
transposition/rounding error that impacted the students Return of Title IV calculation. Recommendation. Management has already taken appropriate corrective action by updating the returns for
the student impacted by the input error. However, we recommend that the College implement a review process
to ensure that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.