Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
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: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Gramm-Leach-Bliley Act (GLBA) Compliance
Material Weakness
DEPARTMENT OF EDUCATION
ALN #: 84.268, 84.063, 84.007, 84.033, and 84.038 Student Financial Assistance Cluster
Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not sufficiently comply with the updated requirements of GLBA.
Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0
Context: San Diego Christian College has not sufficiently documented its written information security programs, its security risk assessment and safeguards, including general threats, not implemented multi-factor authentication on all systems containing personally identifiable information (PII). San Diego Christian College has not implemented continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, San Diego Christian College has not sufficiently implemented an incident response plan, and has not provided a written, annual report to the board. Furthermore, San Diego Christian College has not formalized its employee training program.
Cause: San Diego Christian College has limited resources and has allocated certain staff time and dollars as available to address and document compliance with the requirements of GLBA.
Effect: San Diego Christian College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks.
Identification as repeat finding, if applicable: Not applicable
Recommendation: We commend San Diego Christian College for the work completed on GLBA. We recommend San Diego Christian College allocate sufficient resources to address the remaining requirements of GLBA.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Noncompliance with HCM 1 Monitoring
DEPARTMENT OF EDUCATION
ALN #: 84.033; 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year
Condition: San Diego Christian College did not disburse Federal Work Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) aid before drawing down the funds for the spring 2023 semester
Criteria: 34 CFR 668.162 (a), 34 CFR 668.162 (d)
Questioned Costs: $0
Context: San Diego Christian College inadvertently drew the full 2022-2023 authorization for FWS and FSEOG in December 2022 before the Spring semester began. This resulted in excess cash on hand and non-compliance with Heightened Cash Monitoring, which San Diego Christian College is currently on for cash management. However, San Diego Christian College did comply with these requirements for FDL and Pell during the fiscal year.
Cause: Turnover in staffing.
Effect: Non-compliance with cash management requirement to minimize the time between drawing the Title IV funds and disbursing those funds to students. Non-compliance with HCM requirements for FWS and FSEOG. FWS funds of approximately $34,000 were held for 6 months and FSEOG funds of approximately $25,000 were held for 1 month.
Identification as repeat finding, if applicable: N/A
Recommendation: While San Diego Christian College has procedures for complying with HCM for FDL and Pell, we recommend that a similar process be implemented for FSEOG and FWS to ensure the funds aren't drawn until disbursed to students.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.