Audit 294140

FY End
2023-06-30
Total Expended
$7.05M
Findings
28
Programs
9
Organization: Bay De Noc Community College (MI)
Year: 2023 Accepted: 2024-03-08

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
374465 2023-001 Significant Deficiency - N
374466 2023-001 Significant Deficiency - N
374467 2023-001 Significant Deficiency - N
374468 2023-001 Significant Deficiency - N
374469 2023-001 Significant Deficiency - N
374470 2023-001 Significant Deficiency - N
374471 2023-001 Significant Deficiency - N
374472 2023-002 Significant Deficiency - N
374473 2023-002 Significant Deficiency - N
374474 2023-002 Significant Deficiency - N
374475 2023-002 Significant Deficiency - N
374476 2023-002 Significant Deficiency - N
374477 2023-002 Significant Deficiency - N
374478 2023-002 Significant Deficiency - N
950907 2023-001 Significant Deficiency - N
950908 2023-001 Significant Deficiency - N
950909 2023-001 Significant Deficiency - N
950910 2023-001 Significant Deficiency - N
950911 2023-001 Significant Deficiency - N
950912 2023-001 Significant Deficiency - N
950913 2023-001 Significant Deficiency - N
950914 2023-002 Significant Deficiency - N
950915 2023-002 Significant Deficiency - N
950916 2023-002 Significant Deficiency - N
950917 2023-002 Significant Deficiency - N
950918 2023-002 Significant Deficiency - N
950919 2023-002 Significant Deficiency - N
950920 2023-002 Significant Deficiency - N

Contacts

Name Title Type
Y5BRDNPUAFB5 Lynn Martinson Auditee
9062174070 Joshua Sullivan, CPA Auditor
No contacts on file

Notes to SEFA

Title: 3. Adjustments and Transfers Accounting Policies: The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Bay de Noc Community College (the "College") under programs of the federal government for the year ended June 30, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to and does not present the net position, changes in net position or cash flows of the College. Expenditures reported on the Schedule are reported on the accrual basis of accounting, which is described in Note 1 to the College's financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance or other applicable guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass‐through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: For purposes of charging indirect costs to federal awards, the College has not elected to use the 10 percent de minimis cost rate as permitted by §200.414 of the Uniform Guidance. The College funded $18,000 of the 2021‐2022 Emergency FSEOG that is a part of the Federal Supplemental Educational Opportunity Grant (84.007) by transferring it out of the 2021‐2022 Federal Work‐Study Program (84.033). In addition, the College also funded $23,200 of the 2022‐2023 Emergency FSEOG that is a part of the Federal Supplemental Educational Opportunity Grant (84.007) by transferring it out of the 2022‐2023 Federal Work‐Study Program (84.033).

Finding Details

Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.