2023-001: Student Eligibility and Awarding
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268 – Federal Direct Student Loans
Federal Award Identification Number and Year: P268K231182- 2023
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: During our testing, we noted 1 instance out of 40 students tested at the College where the Subsidized Stafford Loan awarded to the student was less than the maximum amount they were eligible for. An Unsubsidized Stafford Loan was then issued before the maximum subsidized loan amount was awarded.
Questioned Costs: For the instance identified, the student was under awarded $1,000.
Context: The District awarded $1,167,562 in Direct Loans during the year.
Cause: Typographical error based on the department staff member using the values on the student’s loan request form.
Effect: For the instance identified, the student was under awarded the unsubsidized portion of the Stafford Loan.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-006: Unallowable Costs
Federal Agency: Department of Education
Federal Program: COVID-19 Higher Education Emergency Relief Funds (HEERF)/Coronavirus Aid, Relief and Economic Security (CARES) Act – Institutional Portion
Assistance Listing Number: 84.425F
Federal Award Identification Number and Year: P425E205093
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: The Uniform Guidance Cost Principles described in 2 CFR Part 200, Compensation, states that costs of compensation are allowable to the extent that they satisfy the specific requirements of the grant and that total compensation for individual employees is reasonable for the services rendered. Salaries and benefits are allowable for this grant as long as the job duties are a result of responding to the pandemic. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: The District charged unallowable costs to the grant related to an employee whose job duties were not related to the pandemic.
Questioned Costs: $3,341
Context: The District expended $1,951,384 in HEERF – Institutional Portion funds for direct costs during the fiscal year. The value of the sample tested was $22,736.
Cause: The District charged payroll costs for an employee in error.
Effect: Noncompliance with allowable cost principles.
Repeat Finding: This was not a finding in the prior year.
Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-001: Student Eligibility and Awarding
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.268 – Federal Direct Student Loans
Federal Award Identification Number and Year: P268K231182- 2023
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: During our testing, we noted 1 instance out of 40 students tested at the College where the Subsidized Stafford Loan awarded to the student was less than the maximum amount they were eligible for. An Unsubsidized Stafford Loan was then issued before the maximum subsidized loan amount was awarded.
Questioned Costs: For the instance identified, the student was under awarded $1,000.
Context: The District awarded $1,167,562 in Direct Loans during the year.
Cause: Typographical error based on the department staff member using the values on the student’s loan request form.
Effect: For the instance identified, the student was under awarded the unsubsidized portion of the Stafford Loan.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew.
Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample.
Questioned Costs: None.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353.
Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations.
Effect: The cause identified resulted in noncompliance with Title IV regulations.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60
days.
Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly.
Questioned Costs: None.
Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample.
Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above.
Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe.
Questioned Costs: Unknown.
Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population.
Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations
Effect: The District was unable to establish compliance with the Title IV regulation.
Repeat Finding: Yes, see Finding 2022-005.
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance
Federal Agency: Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: Various
Federal Award Identification Number and Year: Various
Award Period: July 1, 2022 through June 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters
Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers.
Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements.
Questioned Costs: None.
Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act.
Cause: The District's information security policy is still in draft form.
Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act.
Repeat Finding: This was not a finding in the prior year.
Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-006: Unallowable Costs
Federal Agency: Department of Education
Federal Program: COVID-19 Higher Education Emergency Relief Funds (HEERF)/Coronavirus Aid, Relief and Economic Security (CARES) Act – Institutional Portion
Assistance Listing Number: 84.425F
Federal Award Identification Number and Year: P425E205093
Award Period: July 1, 2022 to June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria: The Uniform Guidance Cost Principles described in 2 CFR Part 200, Compensation, states that costs of compensation are allowable to the extent that they satisfy the specific requirements of the grant and that total compensation for individual employees is reasonable for the services rendered. Salaries and benefits are allowable for this grant as long as the job duties are a result of responding to the pandemic. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.
Condition: The District charged unallowable costs to the grant related to an employee whose job duties were not related to the pandemic.
Questioned Costs: $3,341
Context: The District expended $1,951,384 in HEERF – Institutional Portion funds for direct costs during the fiscal year. The value of the sample tested was $22,736.
Cause: The District charged payroll costs for an employee in error.
Effect: Noncompliance with allowable cost principles.
Repeat Finding: This was not a finding in the prior year.
Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review.
Views of responsible officials: Management concurs with the finding and plans to correct the finding.