Audit 306769

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated and did not return funds timely for Return to Title IV (R2T4) calculations. The College also did not have formal procedures in place to review the Return to Title IV calculations. Questioned costs: None Context: During our testing of 11 R2T4 calculations, we identified that 3 had mechanically incorrect calculations by using the incorrect number of scheduled break days. Also, during our testing, we identified 1 instance of payment returned later than 45 days after determination of withdrawal. Furthermore, we were unable to identify a formal control procedure related to Return to Title IV transactions. Cause: The College was using the incorrect number of scheduled break days for Spring Semester. Effect: The College could return incorrect amounts based off of their calculations, which could effect student repayment amounts based off of amount earned. Repeat Finding: No Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F204449 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per Uniform Guidance 2 CFR 180.300 nonfederal entities entering into covered transactions must verify the party is not suspended or debarred from conducting business by the federal government. This can be performed by: Checking SAM exclusions, collecting a certification from the party, or adding a clause or condition to the covered transaction. Condition: The College did not maintain documentation indicating the date the SAM check was completed to determine if this was before entering into a covered transaction. Questioned costs: None Context: A monthly process to review the SAM exclusions list is compared to a listing of vendors with expenditures exceeding $25,000; however documentation of the date of this check is not maintained. Cause: The College did not have a control in place to ensure the SAM exclusion check was performed before entering a covered transaction. Effect: The College could enter a covered transaction with an entity that is suspended or disbarred. Repeat Finding: No Recommendation: We recommend that the College evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.

Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.007, & 84.033 Federal Award Identification Number and Year: P063P221353-2023, P007A221190-2023, & P033A221190-2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure accuracy and completeness of NLSDS enrollment reporting. Condition & Context: The College did not have a formal documented review process in place to ensure NSLDS enrollment files were reviewed prior to submitting to the National Student Clearinghouse. Questioned costs: None. Cause: The review process is currently undocumented and is only communicated verbally. Effect: Failure to properly review NSLDS enrollment reporting files could result in inaccurate or incomplete data being transmitted. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document that the NSLDS enrollment files reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of responsible officials: Management agrees with this finding.