Audit 357265

FY End
2024-06-30
Total Expended
$10.99M
Findings
34
Programs
21
Year: 2024 Accepted: 2025-05-28
Auditor: Scheffel Boyle

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
561637 2024-001 Significant Deficiency - N
561638 2024-002 Significant Deficiency - N
561639 2024-003 Significant Deficiency - N
561640 2024-001 Significant Deficiency - N
561641 2024-002 Significant Deficiency - N
561642 2024-003 Significant Deficiency - N
561643 2024-001 Significant Deficiency - N
561644 2024-002 Significant Deficiency - N
561645 2024-003 Significant Deficiency - N
561646 2024-001 Significant Deficiency - N
561647 2024-002 Significant Deficiency - N
561648 2024-003 Significant Deficiency - N
561649 2024-001 Significant Deficiency - N
561650 2024-002 Significant Deficiency - N
561651 2024-003 Significant Deficiency - N
561652 2024-004 Significant Deficiency - H
561653 2024-004 Significant Deficiency - H
1138079 2024-001 Significant Deficiency - N
1138080 2024-002 Significant Deficiency - N
1138081 2024-003 Significant Deficiency - N
1138082 2024-001 Significant Deficiency - N
1138083 2024-002 Significant Deficiency - N
1138084 2024-003 Significant Deficiency - N
1138085 2024-001 Significant Deficiency - N
1138086 2024-002 Significant Deficiency - N
1138087 2024-003 Significant Deficiency - N
1138088 2024-001 Significant Deficiency - N
1138089 2024-002 Significant Deficiency - N
1138090 2024-003 Significant Deficiency - N
1138091 2024-001 Significant Deficiency - N
1138092 2024-002 Significant Deficiency - N
1138093 2024-003 Significant Deficiency - N
1138094 2024-004 Significant Deficiency - H
1138095 2024-004 Significant Deficiency - H

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $4.25M Yes 3
84.268 Federal Direct Student Loans $1.80M Yes 3
93.575 Child Care and Development Block Grant $510,570 - 0
17.274 Youthbuild $395,116 - 0
84.048 Career and Technical Education -- Basic Grants to States $383,018 - 0
15.611 Wildlife Restoration and Basic Hunter Education and Safety $381,075 - 0
84.425 Education Stabilization Fund $351,082 - 0
84.044 Trio Talent Search $289,733 - 0
84.047 Trio Upward Bound $278,343 - 0
10.069 Conservation Reserve Program $140,828 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $119,500 Yes 3
10.093 Voluntary Public Access and Habitat Incentive Program $101,236 - 0
84.033 Federal Work-Study Program $90,066 Yes 3
47.074 Biological Sciences $81,314 - 0
17.259 Wioa Youth Activities $66,190 - 0
84.002 Adult Education - Basic Grants to States $59,555 - 0
94.006 Americorps State and National 94.006 $53,904 - 0
47.050 Geosciences $50,313 - 0
66.461 Regional Wetland Program Development Grants $37,059 - 0
93.569 Community Services Block Grant $12,791 - 0
15.634 State Wildlife Grants $12,415 - 0

Contacts

Name Title Type
WZVXKJBE3L84 Mary Schulte Auditee
6184683300 Robyn Klingler Auditor
No contacts on file

Notes to SEFA

Title: Note 1: General Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual basis of accounting. 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. Pass-through entity identifying numbers are presented whre available. De Minimis Rate Used: N Rate Explanation: The College uses an indirect cost rate of 41% for on campus programs and a rate of 21% for off campus programs. The accompanying schedule of expenditures of federal awards (the "Schedule") includes federal grant activity of Lewis & Clark Community College (the College) under programs of the federal government for the year ended June 30, 2024. The information in this schedule is presented in accordance with requirements of the 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, it is not intended to and does not present the financial position, changes in net position or cash flows of the College.
Title: Note 3: Loan Program Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual basis of accounting. 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. Pass-through entity identifying numbers are presented whre available. De Minimis Rate Used: N Rate Explanation: The College uses an indirect cost rate of 41% for on campus programs and a rate of 21% for off campus programs. For fiscal year ended June 30, 2024, the College acted as a pass-through agency for Federal Direct Loans (subsidized and unsubsidized) to students in the amount of $1,801,996.
Title: Note 5: Other Federal Award Information Accounting Policies: Expenditures reported on the Schedule of Expenditures of Federal Awards are reported on the modified accrual basis of accounting. 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. Pass-through entity identifying numbers are presented whre available. De Minimis Rate Used: N Rate Explanation: The College uses an indirect cost rate of 41% for on campus programs and a rate of 21% for off campus programs. The College did not receive of administer any federal insurance, loan guarantees, or federal noncash assistance during the fiscal year ended June 30, 2024.

Finding Details

Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Period of Performance. Questioned Costs: $785. Condition: The College requested $785 of reimbursement for expenses that were out of the period of performance. Criteria: Per federal compliance guidelines, expenditures requested for reimbursement have to be incurred during the grant period. Cause: These expenses were incurred in an out of period month but paid in a month that was covered by the grant. In error this expense was requested for reimbursement. The College discovered this error during their end of year closing process and adjusted the expenditures claimed in the October 2024 SF270 report to fix this issue. Effect: The College was not in compliance with Period of Performance requirements. Recommendation: We recommend the College do a double check each quarter to ensure only costs incurred during the grant period are included in the reports for reimbursement. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Period of Performance. Questioned Costs: $785. Condition: The College requested $785 of reimbursement for expenses that were out of the period of performance. Criteria: Per federal compliance guidelines, expenditures requested for reimbursement have to be incurred during the grant period. Cause: These expenses were incurred in an out of period month but paid in a month that was covered by the grant. In error this expense was requested for reimbursement. The College discovered this error during their end of year closing process and adjusted the expenditures claimed in the October 2024 SF270 report to fix this issue. Effect: The College was not in compliance with Period of Performance requirements. Recommendation: We recommend the College do a double check each quarter to ensure only costs incurred during the grant period are included in the reports for reimbursement. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College sent out Direct Loan notification letters that only gave the students 14 days to cancel their loans when the cancellation period is required to be 30 days. There was an instance where the College did not send out a direct loan notification email to a student as required. There was one instance where the post-withdrawal disbursement was calculated correctly but paid out before the federal funds letter was returned by the student authorizing the payment of this disbursement. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirements "Disbursements to or on Behalf of Students" and "Return of Title IV Funds", the College has many requirements pertaining to disbursement of Student Financial Assistance. The College must provide timely notification to the students of the date, amount, right to cancel, and the cancelation procedures. Also, for post-withdrawal disbursements, the College is required to provide notification of the post-withdrawal disbursement to the student or parent and that the post-withdrawal disbursement was made according to the student or parent's instructions. Cause: For the first issue noted in the condition, the College was not aware of the 30 day cancelation period. The second two issues noted in the condition were due to isolated human error. Effect: The College was not in compliance with all the disbursement requirements under Special Tests. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance is paid according to the required disbursement rules. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College had five instances out of the twenty-five tested where a student's enrollment change was not updated within the required sixty days. The College had another instance where the student had graduated but the NSLDS records showed the student went straight from full time to withdrawn. The Department of Education never received a report of the student's graduation. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Enrollment Reporting", the College must accurately notify the Department of Education of changes in student enrollment information at the Campus Level and Program Level and must notify the Department of Education timely of certain changes for Direct Loan Borrowers. Cause: This occurred due to human error as the initial enrollment submission was never sent for the Fall 2023 submission. Effect: Even thought the College was not in compliance with all the Enrollment Reporting requirements, no student direct loan repayment start dates were effected. Recommendation: We recommend the College implement internal control procedures to ensure that all Student Financial Assistance Enrollment Reporting is done accurately and timely. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Special Tests. Questioned Costs: $0. Condition: The College's information security program included all seven required elements. However, the Design and Implementation required element included eight minimum safeguards that must be addressed within that element and those were not included in the policy. Criteria: Per the Student Financial Assistance Program Compliance Supplement, May, 2024, the Special Test compliance requirement "Gramm-Leach-Bliley Act", the College must have a written information security program that addresses seven required elements. Cause: The College was not aware that the eight minimum safeguard elements were required to be in the written program. Effect: The College was not in compliance with all of the Gramm-Leach-Bliley under Special Tests. Recommendation: We recommend the College update the written program to expand the Design and Implementation section to include the required eight minimum safeguards. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Period of Performance. Questioned Costs: $785. Condition: The College requested $785 of reimbursement for expenses that were out of the period of performance. Criteria: Per federal compliance guidelines, expenditures requested for reimbursement have to be incurred during the grant period. Cause: These expenses were incurred in an out of period month but paid in a month that was covered by the grant. In error this expense was requested for reimbursement. The College discovered this error during their end of year closing process and adjusted the expenditures claimed in the October 2024 SF270 report to fix this issue. Effect: The College was not in compliance with Period of Performance requirements. Recommendation: We recommend the College do a double check each quarter to ensure only costs incurred during the grant period are included in the reports for reimbursement. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025
Period of Performance. Questioned Costs: $785. Condition: The College requested $785 of reimbursement for expenses that were out of the period of performance. Criteria: Per federal compliance guidelines, expenditures requested for reimbursement have to be incurred during the grant period. Cause: These expenses were incurred in an out of period month but paid in a month that was covered by the grant. In error this expense was requested for reimbursement. The College discovered this error during their end of year closing process and adjusted the expenditures claimed in the October 2024 SF270 report to fix this issue. Effect: The College was not in compliance with Period of Performance requirements. Recommendation: We recommend the College do a double check each quarter to ensure only costs incurred during the grant period are included in the reports for reimbursement. View of Responsible Officials: Management acknowledges the finding and has prepared a corrective action plan. Anticipated Date of Completion: June 30, 2025