FAC Explorer

Audit 295660

FY End
2023-06-30
Total Expended
$5.95M
Findings
18
Programs
10
Organization: Central Christian College of Kansas and Affiliates (KS)
Year: 2023 Accepted: 2024-03-18
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
380931 2023-004 Significant Deficiency Yes N
380932 2023-004 Significant Deficiency Yes N
380933 2023-005 Significant Deficiency - N
380934 2023-005 Significant Deficiency - N
380935 2023-005 Significant Deficiency - N
380936 2023-005 Significant Deficiency - N
380937 2023-005 Significant Deficiency - N
380938 2023-005 Significant Deficiency - N
380939 2023-006 - - E
957373 2023-004 Significant Deficiency Yes N
957374 2023-004 Significant Deficiency Yes N
957375 2023-005 Significant Deficiency - N
957376 2023-005 Significant Deficiency - N
957377 2023-005 Significant Deficiency - N
957378 2023-005 Significant Deficiency - N
957379 2023-005 Significant Deficiency - N
957380 2023-005 Significant Deficiency - N
957381 2023-006 - - E

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $3.39M Yes 2
84.063 Federal Pell Grant Program $1.17M Yes 3
84.038 Federal Perkins Loan Program $970,640 Yes 1
84.425 Covid-19 Education Stabilization Fund Heerf - Ssarp $196,376 - 0
84.425 Covid-19 Education Stabilization Fund Heerf -- Strengthening Institutions Program $94,950 - 0
84.007 Federal Supplemental Educational Opportunity Grants $71,139 Yes 1
84.033 Federal Work-Study Program $38,710 Yes 1
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $18,022 - 0
84.425 Covid-19 Education Stabilization Fund Heerf -- Student Aid Portion $8,520 - 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772 Yes 1

Contacts

Name Title Type
WAHBVHTVZD74 Leann Moore Auditee
6202410723 Doug McVey, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO THE CONSOLIDATED FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Central Christian College of Kansas and Affiliates under programs of the federal government for the year ended June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Central Christian College of Kansas and Affiliates is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Central Christian College of Kansas and Affiliates under programs of the federal government for the year ended June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Central Christian College of Kansas and Affiliates is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate Central Christian College of Kansas and Affiliates did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.
Title: FEDERAL PERKINS LOAN PROGRAM Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Central Christian College of Kansas and Affiliates under programs of the federal government for the year ended June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Central Christian College of Kansas and Affiliates is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate See the Notes to the SEFA for chart/table
Title: ZONE ALTERNATIVE COMPLIANCE Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Central Christian College of Kansas and Affiliates under programs of the federal government for the year ended June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic consolidated financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If Central Christian College of Kansas and Affiliates is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate The College was operating under the Zone Alternative for failure to meet the Department of Education’s standards of financial responsibility. The College must comply with all the requirements specified for the Zone Alternative. As part of the audit procedures, the College’s compliance with the Zone Alternative including their administration of the heightened cash monitoring payment method, disbursing aid and paying out credit balances before requesting reimbursement and timely notification requirements was tested. No non-compliance with the requirements was noted. The College was released from the zone alternative requirements on March 23, 2023 as they again met the standards of financial responsibility as of June 30, 2022.

Finding Details

Finding 2023-004
Inaccurate and Untimely Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely. Additionally, the College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested for accurate and timely R2T4s, there were 1 late return, 1 post withdraw disbursement was not made and 1 inaccurate return. $3,688 of federal direct loans was returned 15 days late. The post withdraw disbursement of $36 in Pell had not been completed as of the end the audit. Additionally, the inaccurate return resulted in an additional $87 of Pell post withdraw disbursement owed to the student due to the wrong last date of attendance in the R2T4 calculation. Cause: This was an oversight by the College. Effect: Incorrect amount of unearned Title IV funds returned and returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely. Additionally, the College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested for accurate and timely R2T4s, there were 1 late return, 1 post withdraw disbursement was not made and 1 inaccurate return. $3,688 of federal direct loans was returned 15 days late. The post withdraw disbursement of $36 in Pell had not been completed as of the end the audit. Additionally, the inaccurate return resulted in an additional $87 of Pell post withdraw disbursement owed to the student due to the wrong last date of attendance in the R2T4 calculation. Cause: This was an oversight by the College. Effect: Incorrect amount of unearned Title IV funds returned and returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Under Awarding of Pell Based on Enrollment Status DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: 2 students out of 37 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $3,348 Context: Both students were under awarded Pell based on their eligibility. One was under awarded due to a miscalculation on their Pell lifetime eligibility usage (LEU). The other student was under awarded based on their enrollment level. The total of Pell grant under awards was $3,348. Cause: Oversight by management when calculating Pell LEU and calculating cross over Pell. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely. Additionally, the College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested for accurate and timely R2T4s, there were 1 late return, 1 post withdraw disbursement was not made and 1 inaccurate return. $3,688 of federal direct loans was returned 15 days late. The post withdraw disbursement of $36 in Pell had not been completed as of the end the audit. Additionally, the inaccurate return resulted in an additional $87 of Pell post withdraw disbursement owed to the student due to the wrong last date of attendance in the R2T4 calculation. Cause: This was an oversight by the College. Effect: Incorrect amount of unearned Title IV funds returned and returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-004
Inaccurate and Untimely Return of Title IV (R2T4) Funds Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the College did not always return unearned Title IV aid timely. Additionally, the College did not always calculate unearned Title IV funds correctly. Criteria: 34 CFR 668.22 Questioned Costs: $0 Context: Out of 8 students tested for accurate and timely R2T4s, there were 1 late return, 1 post withdraw disbursement was not made and 1 inaccurate return. $3,688 of federal direct loans was returned 15 days late. The post withdraw disbursement of $36 in Pell had not been completed as of the end the audit. Additionally, the inaccurate return resulted in an additional $87 of Pell post withdraw disbursement owed to the student due to the wrong last date of attendance in the R2T4 calculation. Cause: This was an oversight by the College. Effect: Incorrect amount of unearned Title IV funds returned and returns of Title IV funds were not performed timely. Identification as repeat finding, if applicable: 2022-003 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review student's R2T4 calculations and returns to help ensure that internal controls over such process can operate effectively and achieve compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-005
Gramm-Leach-Bliley Act (GLBA) Compliance Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 - Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The College has not documented its compliance with the updated regulations that went into effect in June 2023. Those items include: - sufficiently documented its security risk assessment for all systems containing personally identifiable information (PII) and safeguards - implemented multi-factor authentication on all systems containing personally identifiable information - implemented sufficient ongoing vendor management policies and reviews - implemented an incident response plan including all revised legislation - provided a written, annual report to the board covering all required areas Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: not applicable Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-006
Under Awarding of Pell Based on Enrollment Status DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: 2 students out of 37 were not properly awarded Pell based on enrollment status. Criteria: 34 CFR 690.63(b) Questioned Costs: $3,348 Context: Both students were under awarded Pell based on their eligibility. One was under awarded due to a miscalculation on their Pell lifetime eligibility usage (LEU). The other student was under awarded based on their enrollment level. The total of Pell grant under awards was $3,348. Cause: Oversight by management when calculating Pell LEU and calculating cross over Pell. Effect: Pell was not awarded correctly based on enrollment status. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.