Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 690.63, Pell must be disbursed in the exact amount per Pell payment schedules based on their enrollment status, cost of attendance, and expected family contribution.
Per 34 CFR 673.5, loans can only be disbursed if, combined with the other estimated financial assistance the student receives, it does not exceed the student’s financial need. It is noted that improperly calculating the cost of attendance can result in an incorrect amount of Pell being disbursed, as well as possible over- or under-awarding of overall aid.
Condition/context: Of the 40 students selected for general eligibility testing within the Student Financial Aid Cluster, three students were determined to have received an over-award of Pell and/or loans.
Cause: Western Wyoming Community College (the College) utilized the incorrect cost of attendance, which was based on full-time attendance for two semesters for all students, even if those students were only planning to attend a single semester, and the review processes in place failed to identify errors.
Effect: If the Student Financial Aid Office does not properly calculate and disburse Federal aid to students, the College could possibly lose the right to Federal funding.
Questioned costs: $9,218
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain a more thorough system of review of the cost of attendance and Federal aid calculations in order to ensure that the proper factors for each student are utilized.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: 16 CFR 314.4 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate for the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in §314.4 and shall be reasonably designed to achieve the objectives of this part.
Condition/context: The College has not developed or implemented a written comprehensive information security program that addresses all elements as required by 16 CFR 314.4.
Cause: The College did not fully develop, implement, or maintain policies in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should develop, implement, and maintain an information security program that addresses the requirements of the Gramm-Leach-Bliley Act, and the College should develop controls to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 685.305, the school must use the withdrawal date determined under 34 CFR 668.22(b) or (c), as applicable, for the purpose of reporting the date that the student has withdrawn from the school. In addition, per review of 34 CFR 690.83, an institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires in connection with the funds advanced to it and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.
Per 4.4.6 of the NSLDS Enrollment Reporting Guide, “If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published.”
Per 5.1 of the NSLDS Enrollment Reporting Guide, institutions must “certify enrollment data at least every 60 days.”
Condition/context: Of the 10 students selected for enrollment reporting testing:
• One student’s withdrawn status was not reported to NSLDS.
• Two students’ withdrawn and graduated statuses were not reported timely to NSLDS.
• Two students’ program lengths were improperly reported as 3.214 years rather than two years.
Cause: The Student Financial Aid Office and Records and Registration do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: Improper reporting of student status changes could impact a student’s interest subsidy, repayment status, and/or Maximum Eligibility Period.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office and Records and Registration should implement controls to ensure the proper, accurate, and timely reporting of student status changes and all related pertinent information.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.
Criteria: Per 34 CFR 668.164(e)(2)(viii), under a Tier 1 arrangement, the institution must provide to the Secretary an up-to-date URL for the contract and contract data for publication in a centralized database accessible to the public.
Condition/context: A URL for the contract and contract data has not been provided to the Secretary and is not published in the centralized database.
Cause: The College was unaware of the requirement.
Effect: The College is not compliant with the requirements of using a third-party servicer or financial institution to deliver Title IV credit balances.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should provide an up-to-date URL to the Secretary of the U.S. Department of Education for publication in a centralized database accessible to the public.
Views of responsible officials: Management concurs with the finding. See Exhibit I for the corrective action plan.