2023-004 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063
Federal Award Identification Number and Year: P063P218567-20233
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: Of the 60 disbursements tested, one (1) had incorrect disbursement dates to the COD system.
Questioned Costs: None
Context: During our testing, of the 60 disbursements tested, one (1) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat findings: 2022-003
Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Code of Regulations (34 CFR 668.34) Satisfactory academic progress. An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The Secretary considers the institution's policy to be reasonable if:
(1) Provide a policy that, if at the time of each evaluation, the student has not achieved the required GPA, is not successfully completing their program of study at the required pace (if required), or has not completed the program within the maximum time frame, they no longer are eligible for Title IV aid;
(2) Provides specific procedures for disbursements to students on financial aid warning status or financial aid probation status;
(3) If the institution permits the student to appeal a determination, provides specific procedures how the student may reestablish eligibility to receive Title IV; basis on which a student may file an appeal; and information that the student must submit regarding why they failed satisfactory academic progress and how they have changed that will now allow the student to make satisfactory academic progress at the
next evaluation;
(4) If the institution does not permit the student to appeal a determination, describes how a student may reestablish their eligibility to receive Title IV assistance; and
(5) Provides for notification to the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Questioned Costs: None.
Context: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Failure to properly assess student's SAP status based on the policy may result in students receiving funds they are no longer qualified for.
Repeat findings: N/A
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Code of Regulations (34 CFR 668.34) Satisfactory academic progress. An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The Secretary considers the institution's policy to be reasonable if:
(1) Provide a policy that, if at the time of each evaluation, the student has not achieved the required GPA, is not successfully completing their program of study at the required pace (if required), or has not completed the program within the maximum time frame, they no longer are eligible for Title IV aid;
(2) Provides specific procedures for disbursements to students on financial aid warning status or financial aid probation status;
(3) If the institution permits the student to appeal a determination, provides specific procedures how the student may reestablish eligibility to receive Title IV; basis on which a student may file an appeal; and information that the student must submit regarding why they failed satisfactory academic progress and how they have changed that will now allow the student to make satisfactory academic progress at the
next evaluation;
(4) If the institution does not permit the student to appeal a determination, describes how a student may reestablish their eligibility to receive Title IV assistance; and
(5) Provides for notification to the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Questioned Costs: None.
Context: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Failure to properly assess student's SAP status based on the policy may result in students receiving funds they are no longer qualified for.
Repeat findings: N/A
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through 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 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight
students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Questioned Costs: None
Context: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight students that enrollment was not certified in 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat findings: 2022-005
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through 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 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight
students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Questioned Costs: None
Context: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight students that enrollment was not certified in 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat findings: 2022-005
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 – NSLDS tracks how many students, included on a
school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine
whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2).
Condition: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Questioned Costs: None
Context: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment
period.
Repeat findings: 2022-006
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 – NSLDS tracks how many students, included on a
school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine
whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2).
Condition: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Questioned Costs: None
Context: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment
period.
Repeat findings: 2022-006
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College has now created a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College
did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Questioned Costs: None
Context: The College now has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Repeat findings: 2022-007
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College has now created a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College
did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Questioned Costs: None
Context: The College now has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Repeat findings: 2022-007
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-004 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063
Federal Award Identification Number and Year: P063P218567-20233
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student.
Condition: Of the 60 disbursements tested, one (1) had incorrect disbursement dates to the COD system.
Questioned Costs: None
Context: During our testing, of the 60 disbursements tested, one (1) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported.
Repeat findings: 2022-003
Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Code of Regulations (34 CFR 668.34) Satisfactory academic progress. An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The Secretary considers the institution's policy to be reasonable if:
(1) Provide a policy that, if at the time of each evaluation, the student has not achieved the required GPA, is not successfully completing their program of study at the required pace (if required), or has not completed the program within the maximum time frame, they no longer are eligible for Title IV aid;
(2) Provides specific procedures for disbursements to students on financial aid warning status or financial aid probation status;
(3) If the institution permits the student to appeal a determination, provides specific procedures how the student may reestablish eligibility to receive Title IV; basis on which a student may file an appeal; and information that the student must submit regarding why they failed satisfactory academic progress and how they have changed that will now allow the student to make satisfactory academic progress at the
next evaluation;
(4) If the institution does not permit the student to appeal a determination, describes how a student may reestablish their eligibility to receive Title IV assistance; and
(5) Provides for notification to the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Questioned Costs: None.
Context: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Failure to properly assess student's SAP status based on the policy may result in students receiving funds they are no longer qualified for.
Repeat findings: N/A
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-005 Eligibility
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Code of Regulations (34 CFR 668.34) Satisfactory academic progress. An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. The Secretary considers the institution's policy to be reasonable if:
(1) Provide a policy that, if at the time of each evaluation, the student has not achieved the required GPA, is not successfully completing their program of study at the required pace (if required), or has not completed the program within the maximum time frame, they no longer are eligible for Title IV aid;
(2) Provides specific procedures for disbursements to students on financial aid warning status or financial aid probation status;
(3) If the institution permits the student to appeal a determination, provides specific procedures how the student may reestablish eligibility to receive Title IV; basis on which a student may file an appeal; and information that the student must submit regarding why they failed satisfactory academic progress and how they have changed that will now allow the student to make satisfactory academic progress at the
next evaluation;
(4) If the institution does not permit the student to appeal a determination, describes how a student may reestablish their eligibility to receive Title IV assistance; and
(5) Provides for notification to the students of their results of an evaluation that impacts their eligibility for Title IV.
Condition: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Questioned Costs: None.
Context: Of the sixty (60) students tested for eligibility, one (1) student was on suspension status after the Spring 2022 semester due to not meeting the 67% completion rate and continued to fall below the completion rate in Fall 2022 and Spring 2023 semesters. Student did not receive a letter of suspension because they were meeting the GPA requirement and the Financial Aid office was not assessing completion status. The student's account showed a SAP status of Suspension for the 3 semesters; however, the student did not receive a letter of suspension or submit an appeal to continue to receive Aid.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: Failure to properly assess student's SAP status based on the policy may result in students receiving funds they are no longer qualified for.
Repeat findings: N/A
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through 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 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight
students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Questioned Costs: None
Context: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight students that enrollment was not certified in 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat findings: 2022-005
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-006 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through 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 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. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly.
Condition: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight
students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Questioned Costs: None
Context: Out of the eight students, from a statistically valid sample, we noted all eight (8) students status changes were reported after the 60-day reporting requirement. We also noted for the same eight students that enrollment was not certified in 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period.
Repeat findings: 2022-005
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 – NSLDS tracks how many students, included on a
school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine
whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2).
Condition: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Questioned Costs: None
Context: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment
period.
Repeat findings: 2022-006
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-007 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 – NSLDS tracks how many students, included on a
school’s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine
whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2).
Condition: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Questioned Costs: None
Context: Out of the sample of eight students, we noted two (2) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment
period.
Repeat findings: 2022-006
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College has now created a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College
did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Questioned Costs: None
Context: The College now has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Repeat findings: 2022-007
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.
2023-008 Special Tests and Provisions
Federal Agency: U.S. Department of Education
Federal Program Title: Student Financial Assistance Cluster
Assistance Listing No. 84.063, 84.268
Federal Award Identification Number and Year: P063P218567-2023, P268K228567-2023
Award Periods: July 1, 2022 through June 30, 2023
Type of Finding:
- Significant Deficiency in Internal Control Over Compliance
- Other Matters
Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College has now created a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College
did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Questioned Costs: None
Context: The College now has a Written Information Security Program; however, the College did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the College did not designate a qualified individual responsible for overseeing and implementing the information and security program.
Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements.
Effect: There is a risk the College’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner.
Repeat findings: 2022-007
Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements.
Views of Responsible Officials: There is no disagreement with the audit finding.