Audit 299430

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a changes in third party servicers. Condition: During our testing, two companies used for Perkins loan collections should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the College uses two different companies for Perkins loan collections. The third party servicer page was not update to properly reflect the College’s third-party servicers. Cause: The ECAR was not updated when the College signed a contract with the loan collection agencies. Effect: The College is not in compliance with Department of Education requirements that states the ECAR must have accurately reported information. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted one out of eight students tested, effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Questioned costs: None Context: We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause: The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat finding: Yes Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not have a written information security program and there was no documentation that the minimum elements were being addressed. Cause: The College is working with a third-party servicer to become in compliance but the written policies were not in place during the year. Effect: The student personal information could be vulnerable. Repeat finding: Yes Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or specific requirement: Under the Higher Education Act of 1965, as amended, institutions that participate in campus based programs must complete a FISAP annually. Condition: Under an institution’s Program Participation Agreement with the Department of Education institutions are required to report the number of students and dollars spent on campus based programs. Questioned costs: None Context: During our audit procedures, it was noted the College did not properly report the student counts on the FISAP. In Part II, Section F, the number of automatic zero EFC’s was reported too high by 30 students. In addition, two other counts were off by one student. In Part VI, Section A, there were two counts that were off by one student and one student was reported on the wrong line item. Cause: The College does not have a review system in place to catch errors before they are submitted to the Department of Education. Effect: Student data on the FISAP is incorrectly reported. Repeat finding: No Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.