2023-001: Special Tests - Number of Students Served (Significant Deficiency)
Assistance Listing Number and Title: #84.334, Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP)
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): University of Wyoming
Award Number/Name: P334S170010-21
Award Year: September 26, 2021 - September 25, 2022
Criteria: Per the Sub-Award Agreement between the University of Wyoming and Eastern Wyomign College (the College or the Contractor), “Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students:
• GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).”
Condition/context: The number of students served by the College during the year was recorded at 327, an underserving of 23.
Cause: The College has historically been able to meet the minimum required number of students served via internal tracking, as well as via subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR-UP program experienced a turnover in the director position (including a more-than-two-month vacancy). As such, the program struggled to recruit and retain students served via the program. Additionally, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure the minimum required number of students were being served.
Effect: The University of Wyoming could opt to not renew the College’s program funding if the minimum required number of students served is not met.
Questioned costs: None.
Identification as a repeat finding: Yes. See prior-year finding 2022-004.
Recommendation: We recommend that the program have a process in place to ensure that all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.”
Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.”
Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.”
Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.”
Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.”
Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors:
• Two instances in which the students were not reported as withdrawn;
• One instance in which the student’s published program length was incorrect; and
• Two instances in which the reported Program Begin Date did not match institution records.
Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-003: Student Financial Aid Cluster - Special Tests: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Number and Title: #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 668.165, if the institution disburses funds that include Federal Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, unsubsidized loans, and PLUS loans. The institution must notify the student or parent of (i) the anticipated date and amount of the disbursement, (ii) the student’s or parent’s right to cancel all or a portion of that loan, and (iii) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. The institution must provide the notice no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution.
Condition/context: During our review of students who were disbursed Federal direct loans, we noted two students in which the College did not provide written notification to borrowers regarding loan disbursements within 30 days prior/subsequent to the disbursement. Both instances of missed notification occurred in spring 2023.
Cause: The Student Financial Aid Office did not have sufficient controls in place to ensure that notifications were provided and records were maintained.
Effect: The borrower is not aware of the anticipated disbursement date or amount, their right to cancel all or a portion of the loan, or the procedures to follow to cancel the loan if necessary.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office should develop a process to ensure that timely written notification is provided to borrowers regarding loan disbursements and that documentation of notification is maintained.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-001: Special Tests - Number of Students Served (Significant Deficiency)
Assistance Listing Number and Title: #84.334, Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP)
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): University of Wyoming
Award Number/Name: P334S170010-21
Award Year: September 26, 2021 - September 25, 2022
Criteria: Per the Sub-Award Agreement between the University of Wyoming and Eastern Wyomign College (the College or the Contractor), “Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students:
• GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).”
Condition/context: The number of students served by the College during the year was recorded at 327, an underserving of 23.
Cause: The College has historically been able to meet the minimum required number of students served via internal tracking, as well as via subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR-UP program experienced a turnover in the director position (including a more-than-two-month vacancy). As such, the program struggled to recruit and retain students served via the program. Additionally, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure the minimum required number of students were being served.
Effect: The University of Wyoming could opt to not renew the College’s program funding if the minimum required number of students served is not met.
Questioned costs: None.
Identification as a repeat finding: Yes. See prior-year finding 2022-004.
Recommendation: We recommend that the program have a process in place to ensure that all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.”
Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.”
Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.”
Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.”
Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.”
Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors:
• Two instances in which the students were not reported as withdrawn;
• One instance in which the student’s published program length was incorrect; and
• Two instances in which the reported Program Begin Date did not match institution records.
Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-001: Special Tests - Number of Students Served (Significant Deficiency)
Assistance Listing Number and Title: #84.334, Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP)
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): University of Wyoming
Award Number/Name: P334S170010-21
Award Year: September 26, 2021 - September 25, 2022
Criteria: Per the Sub-Award Agreement between the University of Wyoming and Eastern Wyomign College (the College or the Contractor), “Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students:
• GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).”
Condition/context: The number of students served by the College during the year was recorded at 327, an underserving of 23.
Cause: The College has historically been able to meet the minimum required number of students served via internal tracking, as well as via subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR-UP program experienced a turnover in the director position (including a more-than-two-month vacancy). As such, the program struggled to recruit and retain students served via the program. Additionally, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure the minimum required number of students were being served.
Effect: The University of Wyoming could opt to not renew the College’s program funding if the minimum required number of students served is not met.
Questioned costs: None.
Identification as a repeat finding: Yes. See prior-year finding 2022-004.
Recommendation: We recommend that the program have a process in place to ensure that all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.”
Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.”
Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.”
Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.”
Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.”
Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors:
• Two instances in which the students were not reported as withdrawn;
• One instance in which the student’s published program length was incorrect; and
• Two instances in which the reported Program Begin Date did not match institution records.
Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-003: Student Financial Aid Cluster - Special Tests: Disbursements to, or on Behalf of, Students (Significant Deficiency)
Assistance Listing Number and Title: #84.268, Federal Direct Student Loans
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 668.165, if the institution disburses funds that include Federal Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, unsubsidized loans, and PLUS loans. The institution must notify the student or parent of (i) the anticipated date and amount of the disbursement, (ii) the student’s or parent’s right to cancel all or a portion of that loan, and (iii) the procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. The institution must provide the notice no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution.
Condition/context: During our review of students who were disbursed Federal direct loans, we noted two students in which the College did not provide written notification to borrowers regarding loan disbursements within 30 days prior/subsequent to the disbursement. Both instances of missed notification occurred in spring 2023.
Cause: The Student Financial Aid Office did not have sufficient controls in place to ensure that notifications were provided and records were maintained.
Effect: The borrower is not aware of the anticipated disbursement date or amount, their right to cancel all or a portion of the loan, or the procedures to follow to cancel the loan if necessary.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid Office should develop a process to ensure that timely written notification is provided to borrowers regarding loan disbursements and that documentation of notification is maintained.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-001: Special Tests - Number of Students Served (Significant Deficiency)
Assistance Listing Number and Title: #84.334, Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP)
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): University of Wyoming
Award Number/Name: P334S170010-21
Award Year: September 26, 2021 - September 25, 2022
Criteria: Per the Sub-Award Agreement between the University of Wyoming and Eastern Wyomign College (the College or the Contractor), “Subrecipient shall provide services designed to assist in achieving the following objectives for its selected GEAR UP students:
• GEAR UP Wyoming (GUWY) will serve a minimum of 2,000 participants each year. (Contractor is required to serve at least 350 of the 2,000 students).”
Condition/context: The number of students served by the College during the year was recorded at 327, an underserving of 23.
Cause: The College has historically been able to meet the minimum required number of students served via internal tracking, as well as via subrecipient monitoring provided by the University of Wyoming. However, during the year, the GEAR-UP program experienced a turnover in the director position (including a more-than-two-month vacancy). As such, the program struggled to recruit and retain students served via the program. Additionally, the College did not follow its internal procedures to track students served and maintain continuous contact with the University of Wyoming to ensure the minimum required number of students were being served.
Effect: The University of Wyoming could opt to not renew the College’s program funding if the minimum required number of students served is not met.
Questioned costs: None.
Identification as a repeat finding: Yes. See prior-year finding 2022-004.
Recommendation: We recommend that the program have a process in place to ensure that all necessary procedures/controls are adhered to, even in times of positional turnover or when the individuals who usually perform those procedures/controls are on leave.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-002: Student Financial Aid Cluster - Special Tests: Enrollment Reporting (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.268, Federal Direct Student Loans, and #84.063, Federal Pell Grant Program
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: Per 34 CFR 690.83(b)(2), “The Secretary accepts a student’s Payment Data that is submitted in accordance with procedures established through publication in the Federal Register, and that contains information the Secretary considers to be accurate in light of other available information including that previously provided by the student and the institution.”
Per 34 CFR 685.309(b), “Upon receipt of an enrollment report from the Secretary, a school must update all information included in the report and return the report to the Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) Within the timeframe prescribed by the Secretary.”
Per 2.3 of the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, “The accurate administration of the Title IV programs depends heavily on the accuracy of the enrollment information reported by schools and timely and complete enrollment status reporting can help reduce the need for paper deferment forms.”
Per 2.4 of the NSLDS Enrollment Reporting Guide, “NSLDS tracks how many students, included on a school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance.”
Per 3.3 of the NSLDS Enrollment Reporting Guide, “As with any school/servicer arrangement for the administration of Title IV programs, if the school uses an Enrollment Reporting Servicer, the school still has the primary responsibility for submitting timely, accurate, and complete responses to Enrollment Reporting Roster files, and for reporting any changes in student enrollment status in a timely manner.”
Condition/context: Of the seven students selected for testing of accurate enrollment reporting, we noted the following errors:
• Two instances in which the students were not reported as withdrawn;
• One instance in which the student’s published program length was incorrect; and
• Two instances in which the reported Program Begin Date did not match institution records.
Cause: The Student Financial Aid and Registrar Offices do not have controls in place to ensure the proper and timely reporting of student status changes.
Effect: The improper reporting of student status changes could impact students’ interest subsidies and/or repayment status.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The Student Financial Aid and Registrar Offices should implement controls to ensure the proper and timely reporting of student status changes. Upon the implementation of an effective reporting control process, we recommend that the College directly review the student status changes at the NSLDS rather than rely solely on its third-party service provider.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.
2023-004: Student Financial Aid Cluster - Special Tests: Gramm-Leach-Bliley Act - Student Information Security (Significant Deficiency)
Assistance Listing Numbers and Titles: #84.007, #84.033, #84.063 and #84.268, Student Financial Aid Cluster
Federal Agency Name: U.S. Department of Education
Pass-Through Entity Name (if applicable): N/A
Award Number/Name: N/A
Award Year: July 1, 2022 - June 30, 2023
Criteria: 16 CFR 314.3 requires an institution to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the institution’s size and complexity, the nature and scope of activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and be reasonably designed to achieve the objectives of this part.
Condition/context: The College does not have a written comprehensive information security program that addresses all elements required by 16 CFR 314.4.
Cause: The College does not have a control in place to ensure that policies are reviewed and revised in accordance with Federal deadlines.
Effect: The College is not compliant with the Gramm-Leach-Bliley Act.
Questioned costs: None.
Identification as a repeat finding: No.
Recommendation: The College should implement a control to monitor changes in Federal guidelines in order to update policies timely.
Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I for the corrective action plan.