Federal Program Information: COVID – Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Procurement: The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327.
Condition: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance.
Cause: Lack of administrative oversight with respect to procurement process.
Effect or Potential Effect: The College is not in compliance with procurement standards.
Questioned Costs: None.
Context: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College develop and implement a procurement policy conforming to procurement standards.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Enrollment Reporting - The College is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Institutions must also report accurate program and campus level data to the NSLDS. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: Instances were identified where the College failed to submit timely and accurate notification to the NSLDS website for students who graduated and had an increase in attendance during the year.
Instances were also identified where the College did not report accurate program enrollment status or program begin dates for students.
Cause: Lack of administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 3 of 25 students selected for testing, the College did not report accurate program level data to the NSLDS.
For 5 of 29 students selected for testing, the College did not timely report campus level data to NSLDS. Of the 5 students in error, three of those students’ enrollment statuses were not reported accurately.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-007.
Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website correctly and within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Enrollment Reporting - The College is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Institutions must also report accurate program and campus level data to the NSLDS. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: Instances were identified where the College failed to submit timely and accurate notification to the NSLDS website for students who graduated and had an increase in attendance during the year.
Instances were also identified where the College did not report accurate program enrollment status or program begin dates for students.
Cause: Lack of administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 3 of 25 students selected for testing, the College did not report accurate program level data to the NSLDS.
For 5 of 29 students selected for testing, the College did not timely report campus level data to NSLDS. Of the 5 students in error, three of those students’ enrollment statuses were not reported accurately.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-007.
Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website correctly and within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Students Loan Data System (the “NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19).
Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students.
Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements.
Effect or Potential Effect: The College was not in compliance with the transfer monitoring requirements.
Questioned Costs: None.
Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-004.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(2)(i)) require that the institution notify the student, or parent, in writing of (1) the anticipated date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: Instances were identified where the required loan disbursement notification was not sent to the parent borrower.
Cause: Lack of administrative oversight with respect to loan disbursement notification requirements.
Effect or Potential Effect: Parent was not properly notified of award disbursements and/or their right to cancel/decline loan awards. timely
Questioned Costs: None.
Context: For 4 out of 40 students, the College did not send the required loan disbursement notification to the parent borrower.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-005.
Recommendation: We recommend the College enhance procedures over loan disbursement notifications to ensure loan notifications are sent to parent borrowers within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Perkins Loans (ALN #84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Perkins Loan Record Retention: An institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. (i) An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. (ii) If a promissory note was signed electronically, the institution must store it electronically and the promissory note must be retrievable in a coherent format. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied. 34 CFR 674.19(e)(4)
Condition: Instances were identified where a Perkins master promissory note could not be located by the College.
Cause: Lack of administrative oversight with respect to Perkins Loan record retention.
Effect or Potential Effect: The College is not in compliance with Perkins Loan record retention requirements.
Questioned Costs: None.
Context: For 3 of 24 students selected for testing, the College was unable to locate Perkins master promissory note.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-010.
Recommendation: We recommend the College keep inventory of Perkins MPN records kept on campus.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: COVID – Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Procurement: The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327.
Condition: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance.
Cause: Lack of administrative oversight with respect to procurement process.
Effect or Potential Effect: The College is not in compliance with procurement standards.
Questioned Costs: None.
Context: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College develop and implement a procurement policy conforming to procurement standards.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Enrollment Reporting - The College is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Institutions must also report accurate program and campus level data to the NSLDS. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: Instances were identified where the College failed to submit timely and accurate notification to the NSLDS website for students who graduated and had an increase in attendance during the year.
Instances were also identified where the College did not report accurate program enrollment status or program begin dates for students.
Cause: Lack of administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 3 of 25 students selected for testing, the College did not report accurate program level data to the NSLDS.
For 5 of 29 students selected for testing, the College did not timely report campus level data to NSLDS. Of the 5 students in error, three of those students’ enrollment statuses were not reported accurately.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-007.
Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website correctly and within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268), Pell Grants (ALN #84.063)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Enrollment Reporting - The College is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the College becomes aware of the change in enrollment status. Institutions must also report accurate program and campus level data to the NSLDS. Additionally, institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. As with any school/servicer arrangement for the administration of the Title IV programs, if the school uses a third party to meet the NSLDS enrollment reporting requirements it is the school that must ensure that enrollment information is submitted timely, accurately, and completely.
Condition: Instances were identified where the College failed to submit timely and accurate notification to the NSLDS website for students who graduated and had an increase in attendance during the year.
Instances were also identified where the College did not report accurate program enrollment status or program begin dates for students.
Cause: Lack of administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect: The College is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs: None.
Context: For 3 of 25 students selected for testing, the College did not report accurate program level data to the NSLDS.
For 5 of 29 students selected for testing, the College did not timely report campus level data to NSLDS. Of the 5 students in error, three of those students’ enrollment statuses were not reported accurately.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-007.
Recommendation: We recommend the College implement procedures to ensure that all status changes are submitted to the NSDLS website correctly and within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Disbursements to or on Behalf of Students – Transfer Monitoring - If a student received financial aid while attending one or more other institutions, schools are required to request financial aid history using the National Students Loan Data System (the “NSLDS”) Student Transfer Monitoring Process. Under this process, a school informs NSLDS about its transfer students. NSLDS will "monitor" those students on the school's "inform" list and alert the school of any relevant financial aid history changes. A school must wait 7 days after it "informs" NSLDS about a transfer student before disbursing Title IV aid to that student. However, a school does not have to wait if it receives an alert during the 7-day period or if it obtains the student's financial aid history by accessing the NSLDS Financial Aid Professional website. When a school receives an alert from NSLDS, before making a disbursement of Title IV aid, it must determine if the change to the student's financial aid history affects the student's eligibility (34 CFR section 668.19).
Condition: Instances were identified where the College disbursed Title IV aid prior to informing NSLDS about transfer students.
Cause: Lack of administrative oversight and insufficient internal controls with respect to transfer monitoring requirements.
Effect or Potential Effect: The College was not in compliance with the transfer monitoring requirements.
Questioned Costs: None.
Context: For 2 of 2 students selected for testing, the College did not properly inform NSLDS of transfer students prior to disbursing Title IV aid.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-004.
Recommendation: We recommend the College enhance its procedures and internal controls to ensure compliance with transfer monitoring requirements.
Views of Responsible Officials:
Federal Program Information: Federal Direct Student Loans (ALN #84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(2)(i)) require that the institution notify the student, or parent, in writing of (1) the anticipated date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition: Instances were identified where the required loan disbursement notification was not sent to the parent borrower.
Cause: Lack of administrative oversight with respect to loan disbursement notification requirements.
Effect or Potential Effect: Parent was not properly notified of award disbursements and/or their right to cancel/decline loan awards. timely
Questioned Costs: None.
Context: For 4 out of 40 students, the College did not send the required loan disbursement notification to the parent borrower.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-005.
Recommendation: We recommend the College enhance procedures over loan disbursement notifications to ensure loan notifications are sent to parent borrowers within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Return of Title IV Funds: When a recipient of a Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. (34 CFR 668.22(a)(1) through (a)(5)). Once a student’s withdrawal date is determined the institution needs to calculate the percentage of the payment period or period of enrollment completed. The percentage of payment period or period of enrollment completed represents the percentage of aid earned by the student.
An institution must return the amount of Title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section (34 CFR 668.22(j)(1).
Condition: Instance was identified where an incorrect unearned amount of Title IV funds were returned to the Department of Education (the “ED”) beyond the 45 day required timeframe.
Cause: Lack of administrative oversight with respect to Return of Title IV (“R2T4”) calculation.
Effect or Potential Effect: Error in Title IV funds amount and delay in returning to the ED.
Questioned Costs: Amount below reportable threshold.
Context: For 1 of 2 students selected for testing, the College did not return the correct amount to the ED within the required timeframe.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-008.
Recommendation: We recommend the College utilize R2T4 worksheets, complete timely review of R2T4 calculations, and return any Title IV funds to the ED within the required timeframe.
Views of Responsible Officials:
Federal Program Information: Federal Perkins Loans (ALN #84.038)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Perkins Loan Record Retention: An institution shall keep the original promissory notes and repayment schedules until the loans are satisfied. If required to release original documents in order to enforce the loan, the institution must retain certified true copies of those documents. (i) An institution shall keep the original paper promissory note or original paper MPN and repayment schedules in a locked, fireproof container. (ii) If a promissory note was signed electronically, the institution must store it electronically and the promissory note must be retrievable in a coherent format. An original electronically signed MPN must be retained by the institution for 3 years after all the loans made on the MPN are satisfied. 34 CFR 674.19(e)(4)
Condition: Instances were identified where a Perkins master promissory note could not be located by the College.
Cause: Lack of administrative oversight with respect to Perkins Loan record retention.
Effect or Potential Effect: The College is not in compliance with Perkins Loan record retention requirements.
Questioned Costs: None.
Context: For 3 of 24 students selected for testing, the College was unable to locate Perkins master promissory note.
Identification as a Repeat Finding: This is a repeat finding of prior year finding 2022-010.
Recommendation: We recommend the College keep inventory of Perkins MPN records kept on campus.
Views of Responsible Officials:
Federal Program Information: Student Financial Assistance Cluster (Various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Special Tests and Provisions – Gramm-Leach-Bliley Act -Student Information Security - The Gramm-Leach-Bliley Act (Pub. L. No. 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must develop, implement, and maintain a comprehensive information security program to address the required minimum elements set forth in 16 CFR 314.4 (16 CFR 313(a)).
Condition: The College did not maintain a written information security program that addresses the minimum elements.
Cause: Lack of administrative oversight with respect to Gramm- Leach-Bliley Act requirements.
Effect or Potential Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act.
Questioned Costs: None.
Context: The College did not maintain a written information security program that addresses the minimum elements.
Identification as a Repeat Finding: There was no similar finding identified during the prior year.
Recommendation: We recommend the College enhance its procedures with respect to compliance with the requirements of the Gramm-Leach-Bliley Act.
Views of Responsible Officials: