Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 675.20 (d)(1) notes “A student may be employed under the FWS program and also receive academic credit for the work performed. Those jobs include, but are not limited to, work performed when the student is – (i) Enrolled in an internship; (ii) Enrolled in practicum; or (iii) Employed in a research, teaching, or other assistantship.” Further, 34 CFR 675.20 (d)(2) states “A student employed in a FWS job and receiving academic credit for that job may not be – … (ii) Paid for receiving instruction in a classroom, laboratory, or other academic setting.”
Volume 6, Chapter 2 of the 2022-2023 Federal Student Aid Handbook page 4 notes, “In general, students are not permitted to work in FWS positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented.
Condition: During our testing of twenty-five individuals receiving federal work study, we noted three individuals (12%) working during scheduled class hours. We consider this condition to be an instance of non-compliance relating to the Activities Allowed or Unallowed compliance requirement. Statistical sampling was not used in making sample selections.
Questioned Costs: $154
Cause and Effect: Without proper review of hours worked against class hours scheduled, federal work study recipients could receive compensation that is not allowed under the Code of Federal Regulations.
Recommendation: We recommend the College evaluate policies and procedures to ensure work study recipients do not receive compensation for hours worked when they have scheduled class hours.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.164 (a)(1) states “Except as provided under paragraph (a)(2) of this section, a disbursement of title IV, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with- (i) Funds received form the Secretary; (ii) Institutional funds received from a lender under title IV, HEA program funds;
Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-004. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Cause and Effect: The College noted this was an error that occurred but did not occur with the entire batch.
Recommendation: We recommend the College implement procedures in order to report accurate disbursements dates for Direct Loans to NSLDS.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.”
34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60 percent of the payment period or period of enrollment for a program that is measured in credit hours; or…”
34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).”
An institution must notify the student of a post-withdrawal disbursement of Federal Direct Loans used to credit the student’s account for outstanding charges (34 CFR 668.22).
Condition: The College did not timely and accurately complete refund calculations in the Fall. In review of the Fall 2022 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Fall 2022 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 3 out of the population of 3 (100%) Fall withdrawal calculations. A sample of Spring withdrawal calculations identified no errors. We consider this finding to be a material weakness in relation to Special Tests and Provisions and is a repeat finding shown in Section IV of this report as prior year finding 2022-005. Statistical sampling was not used in making sample selections. Questioned Costs: $6
Effect: Miscalculation of the days in the Return of Title IV funds calculations results in incorrect amounts returned by the College.
Recommendation: We recommend the College continually educate themselves on the requirements for the return of title IV fund and ensure the proper controls are implemented to timely and accurately return unearned aid.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: 34 CFR 668.24 (e)(1)(i) states “(1) An institution shall keep records relating to its administration of the Federal Perkins Loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those program, provided an institution shall keep-
“(i) The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information” for three years after the end of the award year in which the FISAP is submitted.”
Condition: The College did not accurately report amounts that agree to supporting documentation retained for the FISAP Report Award Year July 1, 2021, through June 30,2022. The College did not report any amount for Part II total expended state grants and scholarships made to undergraduates for the award year July 1, 2021, to June 30,2022. Per their records this amount should have been $990,483. The College did not accurately report the FWS recipients and funds for Part VI Program Summary for Award Year July 1, 2021, through June 30, 2022. They did not include $1,279,012 in the Federal Work Study that agreed to their retained documentation. We consider this finding to be an instance of noncompliance of internal control over compliance relating to the Reporting compliance requirement.
Questioned Costs: N/A
Effect: The result is the application for the FISAP could affect the Campus-Based program funding for the upcoming year.
Recommendation: We recommend that the College implement procedures in order to properly report amounts on the FISAP that agree to retained documentation.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)).
Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)).
Condition: The College did not implement a risk assessment as part of the new Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information to their student information security policy. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result is the College did not meet the requirements for protecting and securing data obtained from the Department of Education’s systems for the purposes of administering the Title IV programs.
Recommendation: We recommend the College complete a formal risk assessment to adhere the regulations and await guidance from the Department of Education.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.
Criteria: Each student that receives Federal Direct Loans is required to have entrance counseling before release of the first disbursement and exit counseling when they withdraw, graduate, or drop (34 CFR 685.304).
Condition: Three of forty (7.5%) students did not complete exit counseling. This was a result of the Financial Aid Director not being notified that the students were not returning for the Fall 2023 semester. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections.
Questioned Costs: N/A
Effect: The result of not conducting exit counseling is students may be uninformed about the responsibilities and consequences of borrowing funds.
Recommendation: We recommend the College implement procedures to ensure exit counseling is completed and the documentation maintained for loans disbursed.
Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.