FAC Explorer

Audit 356592

FY End
2024-08-31
Total Expended
$35.38M
Findings
14
Programs
13
Organization: Suffolk County Community College (NY)
Year: 2024 Accepted: 2025-05-19
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
560832 2024-003 Significant Deficiency - P
560833 2024-003 Significant Deficiency - P
560834 2024-001 Significant Deficiency - N
560835 2024-002 Significant Deficiency - N
560836 2024-003 Significant Deficiency - N
560837 2024-001 Significant Deficiency - N
560838 2024-002 Significant Deficiency - N
1137274 2024-003 Significant Deficiency - P
1137275 2024-003 Significant Deficiency - P
1137276 2024-001 Significant Deficiency - N
1137277 2024-002 Significant Deficiency - N
1137278 2024-003 Significant Deficiency - N
1137279 2024-001 Significant Deficiency - N
1137280 2024-002 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $24.53M Yes 3
84.268 Federal Direct Student Loans $7.13M Yes 2
84.007 Federal Supplemental Educational Opportunity Grants $771,983 Yes 1
84.042 Trio Student Support Services $318,821 - 0
84.033 Federal Work-Study Program $278,686 Yes 1
47.046 Stem Education (formerly Education and Human Resources) $275,638 - 0
84.425 Education Stabilization Fund $117,968 - 0
84.335 Child Care Access Means Parents in School $100,265 - 0
17.289 Community Project Funding/congressionally Directed Spending $88,083 - 0
47.050 Geosciences $31,064 - 0
84.048 Career and Technical Education -- Basic Grants to States $26,352 - 0
93.859 Biomedical Research and Research Training $20,364 - 0
47.076 Stem Education (formerly Education and Human Resources) $279 - 0

Contacts

Name Title Type
FLKPSYMY25H1 Sara Gorton Auditee
6314514223 Andrew Lee Auditor
No contacts on file

Notes to SEFA

Title: PASS-THROUGH PROGRAMS Accounting Policies: General The accompanying schedule of expenditures of federal awards (Schedule) includes the federal grant activity of the Suffolk County Community College (College), under programs of the federal government for the year ended August 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, and it is not intended to and does not present the financial position of the respective changes in the financial position of the business-type activities of the College. Basis of Accounting Expenditures reported on the Schedule are presented in conformity with accounting principles generally accepted in the United States and the amounts presented are derived from the College’s general ledger. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Where the College receives funds from a government entity other than the federal government (pass-through), the funds are accumulated based upon the Assistance Listing Number advised by the pass-through grantor. Identifying numbers, other than Assistance Listing numbers, which may be assigned bypass- through grantors are not maintained in the College’s financial management system. The College has identified certain pass-through identifying numbers and included them in the Schedule, as available.
Title: INDIRECT COSTS Accounting Policies: General The accompanying schedule of expenditures of federal awards (Schedule) includes the federal grant activity of the Suffolk County Community College (College), under programs of the federal government for the year ended August 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, and it is not intended to and does not present the financial position of the respective changes in the financial position of the business-type activities of the College. Basis of Accounting Expenditures reported on the Schedule are presented in conformity with accounting principles generally accepted in the United States and the amounts presented are derived from the College’s general ledger. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Indirect costs are included in the reported expenditures to the extent they are included in the financial reports used as the source for the expenditures presented. The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: MATCHING COSTS Accounting Policies: General The accompanying schedule of expenditures of federal awards (Schedule) includes the federal grant activity of the Suffolk County Community College (College), under programs of the federal government for the year ended August 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, and it is not intended to and does not present the financial position of the respective changes in the financial position of the business-type activities of the College. Basis of Accounting Expenditures reported on the Schedule are presented in conformity with accounting principles generally accepted in the United States and the amounts presented are derived from the College’s general ledger. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. Matching costs, i.e., the College’s share of certain program costs, are not included in the reported expenditures.
Title: STUDENT LOANS Accounting Policies: General The accompanying schedule of expenditures of federal awards (Schedule) includes the federal grant activity of the Suffolk County Community College (College), under programs of the federal government for the year ended August 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, and it is not intended to and does not present the financial position of the respective changes in the financial position of the business-type activities of the College. Basis of Accounting Expenditures reported on the Schedule are presented in conformity with accounting principles generally accepted in the United States and the amounts presented are derived from the College’s general ledger. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The College also participates in the Guaranteed Student Loan program, Assistance Listing number 84.268, which offers low-interest loans to students and parents. The College is partly responsible for administering the loan program. During the fiscal year 2023-2024, total loans under this program amounted to $7,129,061, including supplemental loans to students.
Title: STUDENT FINANCIAL AID AND INSTITUTIONAL PROGRAM ELIGIBILITY METRICS Accounting Policies: General The accompanying schedule of expenditures of federal awards (Schedule) includes the federal grant activity of the Suffolk County Community College (College), under programs of the federal government for the year ended August 31, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the College, and it is not intended to and does not present the financial position of the respective changes in the financial position of the business-type activities of the College. Basis of Accounting Expenditures reported on the Schedule are presented in conformity with accounting principles generally accepted in the United States and the amounts presented are derived from the College’s general ledger. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The College did not elect to use the 10 percent de minimis indirect cost rate as allowed under the Uniform Guidance. The College is in compliance with the following institutional and program eligibility requirements under the Higher Education Act of 1965 and Federal regulations under 34 CFR 668.23: - Correspondence courses the institution offers under 34 CFR 600.7(b) and (g) - Regular students that enroll in correspondence courses under 34 CFR 600.7(b) and (g) - Institution’s regular students that are incarcerated under 34 CFR 600.7(c) and (g) - Completion rates for confined or incarcerated individuals enrolled in non-degree programs at nonprofit institutions under 34 CFR 600.7(c)(3)(ii) and (g) - Institution’s regular students that lack a high school diploma or its equivalent under 34 CFR 600.7(d) and (g) - Completion rates for short-term programs under 34 CFR 668.8(f) and (g) - Placement rates for short-term programs under https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.8 34 CFR 668.8(e)(2).

Finding Details

Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-001
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted the student status changes that were received by NSLDS was outside of the 60-day timeframe for 7 of the 40 students sampled. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) states that: 1) Schools must have some arrangement to report student enrollment data to 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. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2.) Schools must have some arrangements to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted that 1.) the incorrect enrollment effective date was reported to NSLDS for 2 out of the 40 students tested. 2.) the incorrect program enrollment effective date was reported to NSLDS for 1 out of the 40 students tested. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that the enrollment effective dates were accurately reported to NSLDS. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150%limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-001
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted the student status changes that were received by NSLDS was outside of the 60-day timeframe for 7 of the 40 students sampled. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) states that: 1) Schools must have some arrangement to report student enrollment data to 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. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2.) Schools must have some arrangements to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted that 1.) the incorrect enrollment effective date was reported to NSLDS for 2 out of the 40 students tested. 2.) the incorrect program enrollment effective date was reported to NSLDS for 1 out of the 40 students tested. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that the enrollment effective dates were accurately reported to NSLDS. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150%limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-001
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted the student status changes that were received by NSLDS was outside of the 60-day timeframe for 7 of the 40 students sampled. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) states that: 1) Schools must have some arrangement to report student enrollment data to 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. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2.) Schools must have some arrangements to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted that 1.) the incorrect enrollment effective date was reported to NSLDS for 2 out of the 40 students tested. 2.) the incorrect program enrollment effective date was reported to NSLDS for 1 out of the 40 students tested. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that the enrollment effective dates were accurately reported to NSLDS. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150%limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-003
2024 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, and 84.033 Federal Award Identification Number and Year: P268K231902, P063P231902, P007A232974, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) (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). Condition: Under an institution’s 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. Questioned costs: None Context: During our audit procedures, it was noted that the College did not fully comply with the GLBA guidelines such as no formal review of access controls, no evidence of periodic inventory of data, no process to evaluate network changes, and no modification of the written information security program (WISP) based on a penetration test or cyber incidents. Cause: The College policies and procedures did not comply with the Gramm-Leach-Bliley Act (GLBA) guidelines as noted above. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend reviewing and implementing GLBA guidelines in order to explain the College’s information-sharing practices to their customers and to safeguard sensitive data, including student financial information. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-001
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted the student status changes that were received by NSLDS was outside of the 60-day timeframe for 7 of the 40 students sampled. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: No. Recommendation: The College should review their reporting internal controls and procedures to ensure that they require students' statuses to be reported timely to NSLDS as required by federal regulations. The College should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS aligns with the College’s last date of attendance. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Finding 2024-002
2024 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: P268K231902, P063P231902, grants were awarded within the 2022-23 and 2023-24 award years. Award Period: September 1, 2023, through August 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) states that: 1) Schools must have some arrangement to report student enrollment data to 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. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2.) Schools must have some arrangements to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of NSLDS Enrollment Reporting, we noted that 1.) the incorrect enrollment effective date was reported to NSLDS for 2 out of the 40 students tested. 2.) the incorrect program enrollment effective date was reported to NSLDS for 1 out of the 40 students tested. Questioned Costs: N/A Cause: The College policies and procedures did not ensure that the enrollment effective dates were accurately reported to NSLDS. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150%limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: No. Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.