Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk.
Condition: Management’s review of the enrollment reporting did not detect errors on certain student data elements. Certain student records within the NSLDS were identified with inaccurate data elements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: 17 students were identified with inaccurate data elements reported out of a total of 25 students tested. The sample was a statistically valid sample.
Cause: The College’s internal control over compliance for special tests are not operating effectively. The preparer did not update the student’s status into NSLDS resulting in inaccuracies in significant Campus-Level and Program-Level enrollment date elements that ED considers high risk. Additionally, student with status changes were incorrectly reported as withdrawn but upon review of internal documentation, those same students graduated.
Effect: The College incorrectly reported certain Campus-Level and Program-Level records in NSLDS which is information that ED considers high risk and the College’s internal controls over compliance did not detect and correct the errors. Additionally, the College incorrectly reported status changes to NSLDS.
Recommendation: We recommend management review and enhance its review policies and procedures surrounding enrollment reporting submissions to ensure the accuracy of data elements reported to ED. A review performed by an appropriate individual separate from the prepared prior to the submission of the enrollment reports to NSLDS may improve the accuracy of enrollment
reporting. We also recommend management review all students reported to NSLDS to verify they are accurately reported.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements. Management has corrected the errors.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.
Agencies: U.S Department of Education
Federal Assistance Listing Number: 84.038, 84.063, 84.007, 84.033, 84.268, and 84.379
Programs: Student financial assistance cluster
Criteria: The College is required to have documented internal controls in place to monitor compliance over special tests in accordance with the Uniform Guidance. On December 9, 2021, the Federal Trade Commission issued final regulations for 16 Code of Federal Regulations Part 314 to implement the Gramm-Leach-Bliley Act (GLBA) information safeguarding standards that institutions must implement. These regulations significantly modified the requirements that institutions must meet under GLBA. The regulations established minimum standards that institutions must meet. The FTC stated that it “believes many of the requirements set forth in the Final Rule are so fundamental to any information security program that the information security programs of many financial institutions will already include them if those programs are in compliance with the current Safeguards Rule.”
Institutions are required to be in compliance with the revised requirements no later June 9, 2023. Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts.
Condition: The College did not have documented controls in place reviewing that the comprehensive information security program was in compliance with the Safeguards Rule and was prepared and in place by June 9, 2023. The College did meet the compliance requirements.
Questioned Costs: The amount of questioned costs could not be determined.
Context: The College is required to have documented controls in place to ensure the College has completed information security program available on or before June 9, 2023. Management could not provide documentation that a review occurred.
Cause: The College did not have proper documented controls in place to ensure that the College was compliant with GLBA Safeguards requirements in the timeframe specified by 16 CFR Part 314.
Effect: The ability to adequately safeguard student electronic data may be compromised if the College does not have controls in place to ensure that a timely-prepared information security program to define the various ways in which data is protected is completed.
Recommendation: We recommend the College review their policies and procedures in place ensure that the information security program review is documented to support the College’s compliance under the Uniform Guidance.
Management Response: Management agrees and has implemented necessary procedures/controls to ensure the College is in compliance with enrollment requirements.