Audit 290607

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

USDA Community Facilities Loan Reserve Accounts Significant Deficiency U.S. DEPARTMENT OF AGRICULTURE ALN #: 10.766 Community Facilities Loans and Grants Cluster Federal Award Identification #: 0000008718001CFL, 0000009560402CFL, 0000009560403CFL Condition: Under multiple USDA Community Facilities loan agreements, the College is required to administer a loan reserve account in which monthly deposits are to be made for the first 10 years of the loan or until the loan minimum reserve amount is obtained. Criteria: 7 CFR 1942.17(i) Questioned Costs: $0 Context: The College was not properly administering the loan reserves as outlines in their USDA loan agreements. Cause: Due to changes in management since the loans originated, there was a lack of oversight of the continuing loan reserve requirements across the various loan agreements. Effect: The College did not make reserve contributions as required during the fiscal year-ended June 30, 2023. Identification as repeat finding, if applicable: 2022-002. Recommendation: We recommend the College work with their USDA loan representative to understand their USDA loan reserve requirements for all active and future loan agreements. Additionally, the College should establish the minimum reserve funds that have not been established as of June 30, 2023, and make monthly payments to the reserve account, as outlined in their loan agreements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not always awarded the proper Pell Grant based on their enrollment level. Criteria: 34 CFR 690.63(b) Questioned Costs: $2,272 Context: Out of 34 students tested for proper Pell Grant based on enrollment level, there were 2 students who were under-awarded for Pell Grant for the Summer 2023 term. During the audit, the College disbursed an additional $2,586 in Pell Grants to correct this error. Additionally, there was 1 student who was over-awarded Pell by $2,272. This was returned to the Department during the audit. Cause: Oversight by management. Effect: Pell was not awarded correctly based on enrollment. Identification as repeat finding, if applicable: 2022-003. Recommendation: We recommend that the College review summer Pell Grant disbursements to ensure they reflect the student’s summer enrollment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Monthly Reconciliations of Pell Grant and Federal Direct Loans DEPARTMENT OF EDUCATIONALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Under Federal Financial Responsibility regulations and Federal Direct Loan regulations, the College is required to reconcile the Pell Grants and Direct Loans disbursed between Common Origination and Disbursement (COD), the student information system, and student accounts on a monthly basis. This reconciliation should be on a student-by-student basis to identify any discrepancies between systems. Additionally, any discrepancies that arise during the reconciliation process should be resolved at that time. Criteria: 34 CFR 685.300(b)(5) and 34 CFR 668 Subpart L Questioned Costs: $0 Context: During the fiscal year-end, the College was not completing monthly reconciliations on a timely basis between COD, the student information system, and student accounts. Cause: Due to turnover in key management positions, the College was not able to always reconcile Federal Direct Loans and Pell Grants in a timely manner. Effect: There were students in the sample tested that did not have the correct disbursement dates reported to COD. Additionally, there could be discrepancies between systems that could impact student eligibility and institutional eligibility for Federal Student Aid that would. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement monthly reconciliations and resolve any discrepancies noted during this process to maintain compliance with Federal Student Financial Aid regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Monthly Reconciliations of Pell Grant and Federal Direct Loans DEPARTMENT OF EDUCATIONALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Under Federal Financial Responsibility regulations and Federal Direct Loan regulations, the College is required to reconcile the Pell Grants and Direct Loans disbursed between Common Origination and Disbursement (COD), the student information system, and student accounts on a monthly basis. This reconciliation should be on a student-by-student basis to identify any discrepancies between systems. Additionally, any discrepancies that arise during the reconciliation process should be resolved at that time. Criteria: 34 CFR 685.300(b)(5) and 34 CFR 668 Subpart L Questioned Costs: $0 Context: During the fiscal year-end, the College was not completing monthly reconciliations on a timely basis between COD, the student information system, and student accounts. Cause: Due to turnover in key management positions, the College was not able to always reconcile Federal Direct Loans and Pell Grants in a timely manner. Effect: There were students in the sample tested that did not have the correct disbursement dates reported to COD. Additionally, there could be discrepancies between systems that could impact student eligibility and institutional eligibility for Federal Student Aid that would. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement monthly reconciliations and resolve any discrepancies noted during this process to maintain compliance with Federal Student Financial Aid regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 75 students tested, 7 students were not reported as withdrawn to NSLDS. All students were corrected during the audit. Cause: The registrar’s office was not updating NSLDS in a timely manner when students were reported as withdrawn. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn in NSLDS in a timely manner. We recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 75 students tested, 7 students were not reported as withdrawn to NSLDS. All students were corrected during the audit. Cause: The registrar’s office was not updating NSLDS in a timely manner when students were reported as withdrawn. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn in NSLDS in a timely manner. We recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not retain evidence of providing exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 5 students tested for exit counseling, 3 did not have documentation that exit counseling instructions were sent timely. The College sent exit counseling instructions to the students in the sample during the audit. Cause: With transitions in personnel in the financial aid office, documentation of notifying students was not available. Effect: Exit counseling packets assist in reducing the default rate and is a requirement for all students with Federal Direct Loans. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College develop a system to document that exit counseling instructions are sent to all students and to assist in reducing the College’s default rate. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Inaccurate Return of Title IV Funds (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, and 84.007 Federal Supplemental Education Opportunity Grant Program Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always accurately return unearned Title IV aid. Criteria: 34 CFR 668.22 Questioned Costs: $7,324 Context: Out of 18 students tested for accurate return of Title IV funding, there were 6 students whose return to Title IV amount did not reflect the amount calculated on the Return to Title IV form. This oversight resulted in an additional $1,429 in PLUS Loans, $1550 in Subsidized Loans, $2,970 in Unsubsidized Loans, and $1,375 in Pell to be returned to the Department of Education (the Department). The College returned all funds to the Department during the course of the audit. Additionally, of these 18 students, there were 3 whose returns were late. Cause: Oversight by the College. Effect: Incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement a review of returns on a regular basis to ensure that the amounts calculated on the Return to Title IV form reconcile with what was returned on the student’s account and what was returned to the Department. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans, 84.063 Federal Pell Grants, 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study, and 84.379 TEACH grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, implemented multi-factor authentication on systems containing personally identifiable information (PII), or implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board Cause: The College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We commend the College for the work completed on GLBA. We recommend the College allocate sufficient resources to address the remaining requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

USDA Community Facilities Loan Reserve Accounts Significant Deficiency U.S. DEPARTMENT OF AGRICULTURE ALN #: 10.766 Community Facilities Loans and Grants Cluster Federal Award Identification #: 0000008718001CFL, 0000009560402CFL, 0000009560403CFL Condition: Under multiple USDA Community Facilities loan agreements, the College is required to administer a loan reserve account in which monthly deposits are to be made for the first 10 years of the loan or until the loan minimum reserve amount is obtained. Criteria: 7 CFR 1942.17(i) Questioned Costs: $0 Context: The College was not properly administering the loan reserves as outlines in their USDA loan agreements. Cause: Due to changes in management since the loans originated, there was a lack of oversight of the continuing loan reserve requirements across the various loan agreements. Effect: The College did not make reserve contributions as required during the fiscal year-ended June 30, 2023. Identification as repeat finding, if applicable: 2022-002. Recommendation: We recommend the College work with their USDA loan representative to understand their USDA loan reserve requirements for all active and future loan agreements. Additionally, the College should establish the minimum reserve funds that have not been established as of June 30, 2023, and make monthly payments to the reserve account, as outlined in their loan agreements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not always awarded the proper Pell Grant based on their enrollment level. Criteria: 34 CFR 690.63(b) Questioned Costs: $2,272 Context: Out of 34 students tested for proper Pell Grant based on enrollment level, there were 2 students who were under-awarded for Pell Grant for the Summer 2023 term. During the audit, the College disbursed an additional $2,586 in Pell Grants to correct this error. Additionally, there was 1 student who was over-awarded Pell by $2,272. This was returned to the Department during the audit. Cause: Oversight by management. Effect: Pell was not awarded correctly based on enrollment. Identification as repeat finding, if applicable: 2022-003. Recommendation: We recommend that the College review summer Pell Grant disbursements to ensure they reflect the student’s summer enrollment. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Monthly Reconciliations of Pell Grant and Federal Direct Loans DEPARTMENT OF EDUCATIONALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Under Federal Financial Responsibility regulations and Federal Direct Loan regulations, the College is required to reconcile the Pell Grants and Direct Loans disbursed between Common Origination and Disbursement (COD), the student information system, and student accounts on a monthly basis. This reconciliation should be on a student-by-student basis to identify any discrepancies between systems. Additionally, any discrepancies that arise during the reconciliation process should be resolved at that time. Criteria: 34 CFR 685.300(b)(5) and 34 CFR 668 Subpart L Questioned Costs: $0 Context: During the fiscal year-end, the College was not completing monthly reconciliations on a timely basis between COD, the student information system, and student accounts. Cause: Due to turnover in key management positions, the College was not able to always reconcile Federal Direct Loans and Pell Grants in a timely manner. Effect: There were students in the sample tested that did not have the correct disbursement dates reported to COD. Additionally, there could be discrepancies between systems that could impact student eligibility and institutional eligibility for Federal Student Aid that would. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement monthly reconciliations and resolve any discrepancies noted during this process to maintain compliance with Federal Student Financial Aid regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Monthly Reconciliations of Pell Grant and Federal Direct Loans DEPARTMENT OF EDUCATIONALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Under Federal Financial Responsibility regulations and Federal Direct Loan regulations, the College is required to reconcile the Pell Grants and Direct Loans disbursed between Common Origination and Disbursement (COD), the student information system, and student accounts on a monthly basis. This reconciliation should be on a student-by-student basis to identify any discrepancies between systems. Additionally, any discrepancies that arise during the reconciliation process should be resolved at that time. Criteria: 34 CFR 685.300(b)(5) and 34 CFR 668 Subpart L Questioned Costs: $0 Context: During the fiscal year-end, the College was not completing monthly reconciliations on a timely basis between COD, the student information system, and student accounts. Cause: Due to turnover in key management positions, the College was not able to always reconcile Federal Direct Loans and Pell Grants in a timely manner. Effect: There were students in the sample tested that did not have the correct disbursement dates reported to COD. Additionally, there could be discrepancies between systems that could impact student eligibility and institutional eligibility for Federal Student Aid that would. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement monthly reconciliations and resolve any discrepancies noted during this process to maintain compliance with Federal Student Financial Aid regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 75 students tested, 7 students were not reported as withdrawn to NSLDS. All students were corrected during the audit. Cause: The registrar’s office was not updating NSLDS in a timely manner when students were reported as withdrawn. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn in NSLDS in a timely manner. We recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans and 84.063 Federal Pell Grants Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: Out of 75 students tested, 7 students were not reported as withdrawn to NSLDS. All students were corrected during the audit. Cause: The registrar’s office was not updating NSLDS in a timely manner when students were reported as withdrawn. Effect: Inaccurate reporting can impact a student’s loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College put a system in place to ensure that withdrawn students are reported as withdrawn in NSLDS in a timely manner. We recommend that the College complete reconciliations of enrollment status periodically and complete spot checks of enrollment statuses to NSLDS regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Documentation of Exit Counseling DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Direct Loans Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not retain evidence of providing exit counseling to all students who left or did not send exit counseling instructions timely. Criteria: 34 CFR 685.304(b) Questioned Costs: $0 Context: Out of 5 students tested for exit counseling, 3 did not have documentation that exit counseling instructions were sent timely. The College sent exit counseling instructions to the students in the sample during the audit. Cause: With transitions in personnel in the financial aid office, documentation of notifying students was not available. Effect: Exit counseling packets assist in reducing the default rate and is a requirement for all students with Federal Direct Loans. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College develop a system to document that exit counseling instructions are sent to all students and to assist in reducing the College’s default rate. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.