Audit 332657

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Pell Grant Program, and 84.268 Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted that 9 out of 40 students where the published program length per the program enrollment in NSLDS was incorrectly reported. We noted that 5 out of 40 students were not reported by the College within 60 days of their status change. We also noted that 1 student was never reported to NSLDS and 1 student whose campus enrollment was note updated to show a graduated status. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure that all reporting compliance was filed timely. Cause: The College's processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding. The College utilizes a third-party, National Student Clearinghouse (NSC) to report to NSLDS. The College will report to NSC earlier to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Pell Grant Program, and 84.268 Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted that 9 out of 40 students where the published program length per the program enrollment in NSLDS was incorrectly reported. We noted that 5 out of 40 students were not reported by the College within 60 days of their status change. We also noted that 1 student was never reported to NSLDS and 1 student whose campus enrollment was note updated to show a graduated status. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure that all reporting compliance was filed timely. Cause: The College's processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding. The College utilizes a third-party, National Student Clearinghouse (NSC) to report to NSLDS. The College will report to NSC earlier to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Pell Grant Program, and 84.268 Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted that 9 out of 40 students where the published program length per the program enrollment in NSLDS was incorrectly reported. We noted that 5 out of 40 students were not reported by the College within 60 days of their status change. We also noted that 1 student was never reported to NSLDS and 1 student whose campus enrollment was note updated to show a graduated status. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure that all reporting compliance was filed timely. Cause: The College's processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding. The College utilizes a third-party, National Student Clearinghouse (NSC) to report to NSLDS. The College will report to NSC earlier to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Uniform Guidance 34 CFR 668.164(h)(2)(i), title IV credit balance must be paid directly to the student no later than 14 days after the balance occurred. 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. Condition: During our testing, 41 out of 51 credit balance refunds were returned later than 14 days after the credit balance occurred in student account. Questioned costs: None Context: The College was returning credit balance refunds longer than 14 days after they occurred. Cause: The College was holding financial aid balance until student's purchased bookstore items on student accounts. Effect: The students did not have access to their credit balance refunds timely. Repeat Finding: No Recommendation: We recommend the college update procedures around disbursements of credit balances and implement controls to ensure credit balances are being returned timely. Views of responsible officials: There is no disagreement with the audit finding. Prior to FY23 students signed a form acknowledging and authorizing the College to have credit balances held on their account in the event there would be classes added and to purchase books. During FY23 this procedure was discontinued for an unrelated reason and an unintended consequence was not meeting the 14-day requirement. The College is in the process of developing a new procedure which will be implemented in January, 2025.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters 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. Condition: During our testing, we noted the College did not have adequate internal controls designed for properly documented reviews of return of title IV calculations or direct loan reconciliations. Questioned costs: None Context: During our testing, the College did not have formal documentation that return of title IV calculations or direct loan reconciliations were reviewed and approved. Cause: The College did not have formal procedures in place to review return of title IV calculations or direct loan reconciliations. Effect: If not properly reviewed, the College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Also, the direct loan reconciliations could have errors that would not be detected timely. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures surrounding reviews of return of title IV calculations and direct loan reconciliations. Views of responsible officials: There is no disagreement with the audit finding. The return of title IV calculations and the direct loan reconciliations are generated by Colleague and verified by a Financial Aid Staff member utilizing a different method for the calculation. Effective immediately the Financial Director will review the calculation and initial approval.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Pell Grant Program, and 84.268 Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date as well as program enrollment effective date. Changes to a students' status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: During our testing, we noted that 9 out of 40 students where the published program length per the program enrollment in NSLDS was incorrectly reported. We noted that 5 out of 40 students were not reported by the College within 60 days of their status change. We also noted that 1 student was never reported to NSLDS and 1 student whose campus enrollment was note updated to show a graduated status. Questioned costs: None Context: A control system to prevent and detect errors in the reporting process was not created to ensure that all reporting compliance was filed timely. Cause: The College's processes and controls did not ensure that the student status changes were properly and timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: No Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Views of responsible officials: There is no disagreement with the audit finding. The College utilizes a third-party, National Student Clearinghouse (NSC) to report to NSLDS. The College will report to NSC earlier to provide additional time to review and verify that accurate data was transferred from NSC to NSLDS.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the College to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the College's information technology, we noted the College did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: Under an institutions Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The College has continued to make progress in updating the College to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the College work to update the written security program to ensure compliance with all of the required elements. Views of responsible officials: There is no disagreement with the audit finding. While the College's "written" information security program did not include the minimum requirements, all required activities were being performed. The College is in the process of updating its written information security program to achieve compliance with the Gramm-Leach-Bliley Act.