Audit 304126

2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award year. Questioned costs – None reported. Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. 94 Repeat finding – Yes, 2022-003 Recommendation – The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under these programs to ensure their status and all relevant student data is correct on NSLDS. Views of responsible officials and planned corrective actions – Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting.  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007 95 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – The College is not properly identifying students who have withdrawn from the institution for whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and unofficial withdrawals with accurate withdrawal dates for testing. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Repeat finding – No Recommendation – We recommend the College review their policies, procedures and controls to ensure students who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and maintained for those students. We also recommend the College ensure all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans 97 Criteria: OMB Compliance Supplement, OMB No. 1845-0039 – Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/context: During our testing we noted 82 out of 100 disbursement transactions tested where the disbursement date per the students records and the disbursement date per COD did not agree. We noted in 2 out of 100 transactions, the amount per the student record and amount per COD did not agree. Questioned costs: None. Cause/Effect: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Recommendation: The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes.  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award year. Questioned costs – None reported. Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. 94 Repeat finding – Yes, 2022-003 Recommendation – The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under these programs to ensure their status and all relevant student data is correct on NSLDS. Views of responsible officials and planned corrective actions – Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting.  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007 95 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – The College is not properly identifying students who have withdrawn from the institution for whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and unofficial withdrawals with accurate withdrawal dates for testing. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Repeat finding – No Recommendation – We recommend the College review their policies, procedures and controls to ensure students who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and maintained for those students. We also recommend the College ensure all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans 97 Criteria: OMB Compliance Supplement, OMB No. 1845-0039 – Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/context: During our testing we noted 82 out of 100 disbursement transactions tested where the disbursement date per the students records and the disbursement date per COD did not agree. We noted in 2 out of 100 transactions, the amount per the student record and amount per COD did not agree. Questioned costs: None. Cause/Effect: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Recommendation: The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes.  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 18 disbursements to students out of a population of 113 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the College did not have a documented plan that clearly outlined the plan for disbursement. Additionally, we were unable to obtain clear documentation of the rationale for approval of award amounts for students selected. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The College did not have the controls in place to formerly approve a plan for distribution of funds that was documented and circulated to the College. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – No Recommendation – We recommend the College adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds were to be distributed to students. Views of responsible officials and planned corrective actions – Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Michael N. Espinoza, Vice President of Student ServicesCorrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the audit process. Three independent outreach efforts were implemented to contact, support, and release funding to students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect execution. Documentation was provided for all sample disbursements with a few instances of missing documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF funding was distributed to students that met eligibility requirements within the June 30, 2023, disbursement deadline. Ongoing efforts include the following:  The college will continue to archive and document all disbursement records.  Continued implementation of processes and procedures for all aid disbursement to prevent future instances. Anticipated Completion Date: Completed June 30, 2023

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024

2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award year. Questioned costs – None reported. Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. 94 Repeat finding – Yes, 2022-003 Recommendation – The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under these programs to ensure their status and all relevant student data is correct on NSLDS. Views of responsible officials and planned corrective actions – Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting.  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007 95 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – The College is not properly identifying students who have withdrawn from the institution for whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and unofficial withdrawals with accurate withdrawal dates for testing. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Repeat finding – No Recommendation – We recommend the College review their policies, procedures and controls to ensure students who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and maintained for those students. We also recommend the College ensure all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans 97 Criteria: OMB Compliance Supplement, OMB No. 1845-0039 – Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/context: During our testing we noted 82 out of 100 disbursement transactions tested where the disbursement date per the students records and the disbursement date per COD did not agree. We noted in 2 out of 100 transactions, the amount per the student record and amount per COD did not agree. Questioned costs: None. Cause/Effect: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Recommendation: The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes.  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award year. Questioned costs – None reported. Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. 94 Repeat finding – Yes, 2022-003 Recommendation – The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under these programs to ensure their status and all relevant student data is correct on NSLDS. Views of responsible officials and planned corrective actions – Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting.  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007 95 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – The College is not properly identifying students who have withdrawn from the institution for whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and unofficial withdrawals with accurate withdrawal dates for testing. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Repeat finding – No Recommendation – We recommend the College review their policies, procedures and controls to ensure students who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and maintained for those students. We also recommend the College ensure all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-007 – Reporting – Material Weakness in Internal Controls Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans 97 Criteria: OMB Compliance Supplement, OMB No. 1845-0039 – Institutions are required to submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the Common Origination and Disbursement (COD). The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition/context: During our testing we noted 82 out of 100 disbursement transactions tested where the disbursement date per the students records and the disbursement date per COD did not agree. We noted in 2 out of 100 transactions, the amount per the student record and amount per COD did not agree. Questioned costs: None. Cause/Effect: The College did not have adequate and/or functioning controls in place to ensure the reporting of disbursements to students on COD was submitted timely and that the dates and amounts agreed. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the disbursement information reported by institutions. The College is not in compliance with the federal COD reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding: Yes, 2022-004 Recommendation: The College should implement a process to review, update, and verify student disbursements are reported to COD accurately and timely. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action: The college will conduct ongoing training to develop reporting and process steps to prevent reporting errors and improve accuracy in reporting in identifying student’s assistance needs. The College has entered into an agreement with a third-party financial aid provider to service and administer financial aid awards, COD reporting and reconciliation.  The College will implement a process to review, update, and verify student disbursements are reported to COD accurately and timely.  Prevention to include creation of reports for awards pending and detailed disbursement and reconciliations schedules, and system back-end processes.  Implemented a tracking log starting in July 2023 between Financial Aid and the Business Office to ensure distribution in compliance with Common Origination and Disbursement (COD). Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 18 disbursements to students out of a population of 113 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the College did not have a documented plan that clearly outlined the plan for disbursement. Additionally, we were unable to obtain clear documentation of the rationale for approval of award amounts for students selected. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The College did not have the controls in place to formerly approve a plan for distribution of funds that was documented and circulated to the College. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – No Recommendation – We recommend the College adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds were to be distributed to students. Views of responsible officials and planned corrective actions – Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Michael N. Espinoza, Vice President of Student ServicesCorrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the audit process. Three independent outreach efforts were implemented to contact, support, and release funding to students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect execution. Documentation was provided for all sample disbursements with a few instances of missing documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF funding was distributed to students that met eligibility requirements within the June 30, 2023, disbursement deadline. Ongoing efforts include the following:  The college will continue to archive and document all disbursement records.  Continued implementation of processes and procedures for all aid disbursement to prevent future instances. Anticipated Completion Date: Completed June 30, 2023

2023-003 – Reporting – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 4 special reports from the population of 4 special reports was selected. For the three quarterly reports selected, the College could not provide support that the reports were published timely. In addition, the College could not provide consistent institutional records for the data included in the three quarterly reports or annual report. Three of the four quarterly reports were corrected based on the audit procedures performed, the College did not properly identify these as “corrected” upon posting to the College website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the lack of controls, the College did not maintain support that quarterly reports were posted timely and was unable to provide consistent institutional records for the data included in the reports. Repeat finding – Yes, 2022-005 Recommendation – We recommend the College update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report, note the reports as “corrected” and ensure institutional records are maintained that clearly support the data reported. We also recommend the College implement a process to ensure evidence of submission dates and publication dates are maintained to ensure compliance with the reporting due dates. Views of responsible officials and planned corrective actions – 93 Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Courtney Judah, Executive Director of Institutional Effectiveness Corrective Action Plan: The college will continue to apply a detailed reporting process for timely collection and reporting of grants. Reporting to include the following:  Accurate and regular collection of data needed to report outcomes and service populations.  Cross verify data with Institutional Effectiveness and Institutional Research.  Post in accordance with grant requirements including documentation to record posting and submission dates. Anticipated Completion Date: Completed April 30, 2024