Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings
Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change.
Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions.
Context: Of our population tested the College had six status changes to the NSLDS after 60 days.
Effect: The College did not report status changes to the NSLDS timely.
Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings
Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change.
Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions.
Context: Of our population tested the College had six status changes to the NSLDS after 60 days.
Effect: The College did not report status changes to the NSLDS timely.
Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-004 - Student Financial Aid Cluster, CFDA# 84.063, 84.268
Compliance Requirement: Reporting
Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement.
Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system.
Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system.
Context: Of the population tested all the disbursement dates in the COD system did not match student records.
Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system.
Management Response: The College concurs with this finding.
Nonmaterial Noncompliance Findings Finding 2024-004 - Student Financial Aid Cluster, CFDA# 84.063, 84.268
Compliance Requirement: Reporting
Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement.
Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system.
Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system.
Context: Of the population tested all the disbursement dates in the COD system did not match student records.
Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system.
Management Response: The College concurs with this finding.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Significant Deficiency
Finding 2024-001 – Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268
Criteria: The College’s system of financial aid and internal controls should be designed to accurately retrieve records so that the College can comply with laws and regulations and be audited under Governmental Auditing Standards and Uniform Grant Guidance. The College’s system of internal controls must appropriately document reviews and approvals of all department of education compliance requirements.
Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals.
Cause: The College changed their system for financial aid and did not appropriately backup historical records. Although they were able to provide all the latest ISIR records, they were not able to provide original ISIR records if a student amended their ISIR.
Recommendation: Particular attention should be placed on systems and process improvements necessary to ensure accurate retention of student records and documentation of reviews and approvals.
Context: Of our population tested the College had 1 record unable to be retrieved out of 40 and the whole population missing support or review and approvals for various requirements.
Effect: The College cannot show appropriate documentation for all records and controls.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings
Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change.
Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions.
Context: Of our population tested the College had six status changes to the NSLDS after 60 days.
Effect: The College did not report status changes to the NSLDS timely.
Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings
Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268
Compliance Requirement: Special Test and Provisions – Enrollment Reporting
Criteria: The College is required to send changes in attendance levels of students, including students who, graduated, withdrew, dropped out, or enrolled changes to the National Student Loan Data System (“NSLDS”) within 60 days of the change.
Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change.
Cause: The College had not reported status changes of students to the NSLDS as required under the Uniform Grant Guidance for the year ended June 30, 2024. The status information reported in the College’s system, was incorrectly tracked for the submission to the National Student Clearinghouse and NSLDS, which created late submissions.
Context: Of our population tested the College had six status changes to the NSLDS after 60 days.
Effect: The College did not report status changes to the NSLDS timely.
Recommendation: The College should put in place a process to timely capture student changes so they can be reported to the NSLDS.
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-003 - Student Financial Aid Cluster, CFDA# 84.007, 84.033, 84.063, 84.268
Compliance Requirement: Gramm-Leach-Bliley Act – Student Information Security
Criteria: The College is required to have a written security program that address the seven elements as described in 16 CFR 314.4 (b).
Condition: The College does not have a written security program that address the seven elements as described in 16 CFR 314.4 (b) as of June 30, 2024.
Cause: Although the College meets some of the seven elements as described in 16 CFR 314.4 (b), the College has yet to establish a formalized written policy.
Context: Not all elements as described in 16 CFR 314.4 (b) have been met, nor is has the College establish a formalized written policy.
Effect: The College could have risks associated with the safeguarding of sensitive information it is not aware of or does not protect against.
Recommendation: The College should review and put in place the required minimum elements as described in 16 CFR 314.4 (b).
Management Response: The College concurs with this finding.
Corrective Action Plan: See attached management’s corrective action plan.
Nonmaterial Noncompliance Findings Finding 2024-004 - Student Financial Aid Cluster, CFDA# 84.063, 84.268
Compliance Requirement: Reporting
Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement.
Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system.
Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system.
Context: Of the population tested all the disbursement dates in the COD system did not match student records.
Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system.
Management Response: The College concurs with this finding.
Nonmaterial Noncompliance Findings Finding 2024-004 - Student Financial Aid Cluster, CFDA# 84.063, 84.268
Compliance Requirement: Reporting
Criteria: The College is required to submit Direct Loan and Pell Grant origination records and disbursement records to the COD system. The disbursement record reports the actual disbursement date and the amount of the disbursement.
Condition: The College does not report the actual disbursement date the student receive the Direct Loan and/or Pell funds to the COD system.
Cause: The College uses the date they report the disbursements to the COD system as the disbursement date. The actual disbursement date the student receives the funds does not match the COD system.
Context: Of the population tested all the disbursement dates in the COD system did not match student records.
Recommendation: The College should put in place a process to accurately capture student disbursement dates to the COD system.
Management Response: The College concurs with this finding.