Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program AL# and Program Expenditure: 84.268 ($857,747) Award Number: P268K247533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $-0- Condition Found: The incorrect withdrawal date was reported to the National Student Loan Database System (“NSLDS”) for nine of the fourteen students selected for testing that received Federal Direct Student Loans. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately within sixty days of the enrollment status change to NSLDS. Cause:The Financial Aid Director used the date students informed the College they were not returning for the next semester as the withdrawal date instead of the last date of attendance for the next semester for seven of the nine students. Additionally, NSLDS was not updated to include Spring 2024 enrollment status changes for the two remaining students associated with the finding. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Director should update the withdrawal dates in NSLDS. Procedures should b3 improved to ensure that the enrollment status change dates entered into NSLDS are accurate and are based off a student’s last date of attendance. Management Response: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Director updated the enrollment status for the students in question in November 2024. Procedures will be improved to ensure that a student’s enrollment status is updated timely and with the correct date of the change.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program AL# and Program Expenditure:84.268 ($857,747) Award Number: P268K247533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $-0- Condition Found: A Federal Direct Loan exit interview was not completed by, nor were instructions sent to, students on how to complete an exit interview when the students graduated from the College or dropped below a halftime enrollment status. This was applicable for five of the fourteen students selected for testing that received Federal Direct Loan funds. Criteria: Federal Direct Loan recipients must receive exit interview counseling. If in-person counseling is not completed, the College may mail written counseling materials to a student’s last known address with thirty days of the date the student withdrew from the College or was attending less than half-time. Cause:Federal Direct Loan exit counseling was not provided when students withdrew from the College or dropped below a halftime enrollment status. This was an oversight on the part of the financial aid office staff. Possible Asserted Effect: The students were not aware of their responsibilities related to the Federal Direct Loan program, including repayment options and when repayment on the loans begin. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Federal Direct Loan exit interview information should be sent to the students in question. Procedures should be improved to ensure that Federal Direct exit interviews are completed or information is sent to a student when a student ceases attendance at the College or drops below a halftime enrollment status. The exit interview should be sent within 30 days of the qualifying event. Management Response: Federal Direct Loan exit interview information was sent to the students in question in November 2024. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the College.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell GrantAL# and Program Expenditure: 84.268 ($857,747) 84.063 ($384,191)Award Number: P268K247533 P063P237533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs:$-0- Condition Found: The College’s information security plan does not include the requirements mandated by the Gramm-Leach-Bliley Act. Criteria: The Gramm-Leach-Bliley Act was updated effective June 9, 2023. According to Electronic Announcement ID: General-23-09, for institutions that maintain student information on less than 5,000 consumers, the information security plan must include the following seven elements. Element 1: Designate a qualified individual responsible for overseeing, implementing, and enforcing the institution’s information and security program. Element 2: Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. Element 3: Provides for the design and implementation of safeguards to control the risks the institution identifies through risk assessment. At the minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c) (1) through (8). Element 4: Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Element 5: Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. Element 6: Addresses how the institution will oversee its information service providers. Element 7: Provides for the evaluation an adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact on the information security programs. Cause: The College’s current information security review does not include the seven elements listed in the criteria. Possible Asserted Effect: The College’s information security report does not meet the requirements listed in the Gramm-Leach-Bliley Act. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The College should update its information security policy to include the elements required by the Gramm-Leach-Bliley Act. The policy should be in writing. Management Response: The College will review its information security policy during FY 2025 and will make the required changes.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell GrantAL# and Program Expenditure: 84.268 ($857,747) 84.063 ($384,191)Award Number: P268K247533 P063P237533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs:$-0- Condition Found: The College’s information security plan does not include the requirements mandated by the Gramm-Leach-Bliley Act. Criteria: The Gramm-Leach-Bliley Act was updated effective June 9, 2023. According to Electronic Announcement ID: General-23-09, for institutions that maintain student information on less than 5,000 consumers, the information security plan must include the following seven elements. Element 1: Designate a qualified individual responsible for overseeing, implementing, and enforcing the institution’s information and security program. Element 2: Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. Element 3: Provides for the design and implementation of safeguards to control the risks the institution identifies through risk assessment. At the minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c) (1) through (8). Element 4: Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Element 5: Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. Element 6: Addresses how the institution will oversee its information service providers. Element 7: Provides for the evaluation an adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact on the information security programs. Cause: The College’s current information security review does not include the seven elements listed in the criteria. Possible Asserted Effect: The College’s information security report does not meet the requirements listed in the Gramm-Leach-Bliley Act. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The College should update its information security policy to include the elements required by the Gramm-Leach-Bliley Act. The policy should be in writing. Management Response: The College will review its information security policy during FY 2025 and will make the required changes.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program AL# and Program Expenditure: 84.268 ($857,747) Award Number: P268K247533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $-0- Condition Found: The incorrect withdrawal date was reported to the National Student Loan Database System (“NSLDS”) for nine of the fourteen students selected for testing that received Federal Direct Student Loans. Criteria: NSLDS informs loan servicers of changes in a student’s enrollment status that indicate when the repayments or interest accrual begins and ends. The date a student enrolls, withdraws, graduates, or drops below half-time status should be reported accurately within sixty days of the enrollment status change to NSLDS. Cause:The Financial Aid Director used the date students informed the College they were not returning for the next semester as the withdrawal date instead of the last date of attendance for the next semester for seven of the nine students. Additionally, NSLDS was not updated to include Spring 2024 enrollment status changes for the two remaining students associated with the finding. Possible Asserted Effect: The loan servicers were not aware of the correct deferral, repayment, and interest calculation dates. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The Financial Aid Director should update the withdrawal dates in NSLDS. Procedures should b3 improved to ensure that the enrollment status change dates entered into NSLDS are accurate and are based off a student’s last date of attendance. Management Response: Management agrees with the auditors’ finding and their recommendation. The Financial Aid Director updated the enrollment status for the students in question in November 2024. Procedures will be improved to ensure that a student’s enrollment status is updated timely and with the correct date of the change.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program AL# and Program Expenditure:84.268 ($857,747) Award Number: P268K247533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs: $-0- Condition Found: A Federal Direct Loan exit interview was not completed by, nor were instructions sent to, students on how to complete an exit interview when the students graduated from the College or dropped below a halftime enrollment status. This was applicable for five of the fourteen students selected for testing that received Federal Direct Loan funds. Criteria: Federal Direct Loan recipients must receive exit interview counseling. If in-person counseling is not completed, the College may mail written counseling materials to a student’s last known address with thirty days of the date the student withdrew from the College or was attending less than half-time. Cause:Federal Direct Loan exit counseling was not provided when students withdrew from the College or dropped below a halftime enrollment status. This was an oversight on the part of the financial aid office staff. Possible Asserted Effect: The students were not aware of their responsibilities related to the Federal Direct Loan program, including repayment options and when repayment on the loans begin. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: Federal Direct Loan exit interview information should be sent to the students in question. Procedures should be improved to ensure that Federal Direct exit interviews are completed or information is sent to a student when a student ceases attendance at the College or drops below a halftime enrollment status. The exit interview should be sent within 30 days of the qualifying event. Management Response: Federal Direct Loan exit interview information was sent to the students in question in November 2024. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they cease enrollment at the College.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell GrantAL# and Program Expenditure: 84.268 ($857,747) 84.063 ($384,191)Award Number: P268K247533 P063P237533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs:$-0- Condition Found: The College’s information security plan does not include the requirements mandated by the Gramm-Leach-Bliley Act. Criteria: The Gramm-Leach-Bliley Act was updated effective June 9, 2023. According to Electronic Announcement ID: General-23-09, for institutions that maintain student information on less than 5,000 consumers, the information security plan must include the following seven elements. Element 1: Designate a qualified individual responsible for overseeing, implementing, and enforcing the institution’s information and security program. Element 2: Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. Element 3: Provides for the design and implementation of safeguards to control the risks the institution identifies through risk assessment. At the minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c) (1) through (8). Element 4: Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Element 5: Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. Element 6: Addresses how the institution will oversee its information service providers. Element 7: Provides for the evaluation an adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact on the information security programs. Cause: The College’s current information security review does not include the seven elements listed in the criteria. Possible Asserted Effect: The College’s information security report does not meet the requirements listed in the Gramm-Leach-Bliley Act. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The College should update its information security policy to include the elements required by the Gramm-Leach-Bliley Act. The policy should be in writing. Management Response: The College will review its information security policy during FY 2025 and will make the required changes.
Federal Agency: U.S. Department of Education; Office of Federal Student Aid Pass through Entity: Not applicable Program Name: Federal Direct Student Loan Program Federal Pell GrantAL# and Program Expenditure: 84.268 ($857,747) 84.063 ($384,191)Award Number: P268K247533 P063P237533 Federal Award Year: July 1, 2023 to June 30, 2024 Questioned Costs:$-0- Condition Found: The College’s information security plan does not include the requirements mandated by the Gramm-Leach-Bliley Act. Criteria: The Gramm-Leach-Bliley Act was updated effective June 9, 2023. According to Electronic Announcement ID: General-23-09, for institutions that maintain student information on less than 5,000 consumers, the information security plan must include the following seven elements. Element 1: Designate a qualified individual responsible for overseeing, implementing, and enforcing the institution’s information and security program. Element 2: Provides for the information security program to be based on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. Element 3: Provides for the design and implementation of safeguards to control the risks the institution identifies through risk assessment. At the minimum, the written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c) (1) through (8). Element 4: Provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented. Element 5: Provides for the implementation of policies and procedures to ensure that personnel are able to enact the information security program. Element 6: Addresses how the institution will oversee its information service providers. Element 7: Provides for the evaluation an adjustment of its information security program in light of the results of the required testing and monitoring; any material changes to its operations or business arrangements; the results of required risk assessments; or any other circumstances that it knows or has reason to know may have a material impact on the information security programs. Cause: The College’s current information security review does not include the seven elements listed in the criteria. Possible Asserted Effect: The College’s information security report does not meet the requirements listed in the Gramm-Leach-Bliley Act. Repeat Finding: There was not a similar finding in the previous year. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: The College should update its information security policy to include the elements required by the Gramm-Leach-Bliley Act. The policy should be in writing. Management Response: The College will review its information security policy during FY 2025 and will make the required changes.