Significant Deficiency – Federal Direct Loan Cash Management
Program: Federal Direct Loan Program
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K234070
Federal Agency: U.S. Department of Education
Federal Award Year: June 30, 2023
Condition: During the Spring semester, the College did not minimize the time between funds transferred and disbursement to students’ accounts.
Criteria: The Advance Payment Method requires that the College disburse the requested funds no later than three business days following receipt of funds received from the Education Department.
Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid.
Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely.
Effect: The College did not disburse federal funds drawn down to the students’ accounts until approximately five weeks after drawdown.
Questioned costs: 1,244,713
Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the advance payment method and establish controls to ensure it complies with the federal requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will ensure staff with compliance responsibilities are appropriately trained and understand the requirements of the program.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Federal Direct Loan Cash Management
Program: Federal Direct Loan Program
Assistance Listing Number: 84.268
Federal Award Identification Number: P268K234070
Federal Agency: U.S. Department of Education
Federal Award Year: June 30, 2023
Condition: During the Spring semester, the College did not minimize the time between funds transferred and disbursement to students’ accounts.
Criteria: The Advance Payment Method requires that the College disburse the requested funds no later than three business days following receipt of funds received from the Education Department.
Context: A review of the entire population of drawdowns for the Student Financial Aid cluster for the entire year was performed and as such, the sample is statistically valid.
Cause: The College did not follow the procedures for requesting federal funds and disbursing them to student accounts timely.
Effect: The College did not disburse federal funds drawn down to the students’ accounts until approximately five weeks after drawdown.
Questioned costs: 1,244,713
Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the advance payment method and establish controls to ensure it complies with the federal requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will ensure staff with compliance responsibilities are appropriately trained and understand the requirements of the program.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.
Significant Deficiency – Gramm-Leach Bliley Act Compliance
Program: Student Financial Aid Cluster
Assistance Listing Number: 84.007; 84.033; 84.063; 84.268
Federal Award Year: June 30, 2023
Condition: The College did not comply with all elements included in the standards for safeguarding customer information as defined under 16 CFR 314.4.
Criteria: 16 CFR 314 requires the College to develop, implement and maintain reasonable administrative technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information.
Cause: The College experienced turnover in its information technology director.
Effect: The College was not fully compliant with all elements of 16 CFR 314.4 that became effective as of June 9, 2023. Specifically, the College was not in compliance with subparagraphs (a), (b)(1), (c)(1), (c)(2), (c)(4) through (8), (d)(2), (e), (f)(3), (h), and (i).
Questioned costs: Not Applicable
Recommendation: The College should take action to establish the above elements of an information security program so it will be in full compliance with this requirement.
Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will modify the design of its existing security program so the College is in full compliance with this requirement.