Audit 358096

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: The 39 students tested for proper NSLDS enrollment status did not have their enrollment updated for the year under audit. Cause: Due to turnover in the financial aid office, NSLDS was not updated accurately for the 22-23 year. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: The 39 students tested for proper NSLDS enrollment status did not have their enrollment updated for the year under audit. Cause: Due to turnover in the financial aid office, NSLDS was not updated accurately for the 22-23 year. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not initially appropriately awarded federal loans based on need. Criteria: 34 CFR 685.200(a) Questioned Costs: $20,719 Context: Out of 39 students tested, 6 students were not awarded aid appropriately based on need analysis. Three students were awarded federal direct subsidized loans in excess of cost of attendance, resulting in a total of $6,728 over awarded to them. Another student was enrolled less than half time, making them eligible for federal direct loans. This resulted an over award of $5,500 in subsidized loans and $6,000 in unsubsidized loans. Additionally, one student declined their loans however they were still disbursed leading to an over award of $2,491 in subsidized loans. Lastly, the remaining student accepted their loans but these were not disbursed, resulting in an under award of $950 subsidized loans and $6,000 unsubsidized loans. Cause: The College identified that there were scholarships in the student information system that were not set up to count towards cost of attendance and need analysis calculations. There were also oversights by the College for students who accepted or declined their loans. Effect: Students received federal loans for which they were not eligible. Identification as repeat finding, if applicable: 2022-007 Recommendation: We recommend the College ensure that all scholarships are marked as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students at the College were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $1,877 Context: Out of 39 students tested for Pell grant eligibility, 6 were not properly awarded Pell awards. Four of these students had an incorrect Pell calculation performed, resulting in $1,877 of Pell over awarded, and one under award of $400. Another 2 students were not paid for classes they began attendance in, leading to a total of $7,307 under awarded to them. Cause: These were oversights by the College. Effect: There was an incorrect amount of Pell paid to these students. Identification as repeat finding, if applicable: 2022-005. Recommendation: We recommend a process be implemented to verify Pell is correctly awarded before disbursements are made. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Two students of 39 tested had COD loan disbursement date errors ranging from 25-153 days, both in the Fall and Spring terms. One student out of 39 tested had COD Pell disbursement date error of 15 days. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend the College implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Two students of 39 tested had COD loan disbursement date errors ranging from 25-153 days, both in the Fall and Spring terms. One student out of 39 tested had COD Pell disbursement date error of 15 days. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend the College implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Lack of Administrative Capability Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 (Student Financial Assistance Cluster) Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The administrative capability is currently below the required level for maintaining compliance with Title IV regulations. Criteria: 34 CFR 668.16 Questioned Costs: $0 Context: In the current year, we found several areas of noncompliance and three repeat findings with the Department of Education regulations due to the fact that the financial aid system was not designed to appropriately support the current level of staffing for financial aid, the complexity of administering financial aid for the various educational programs, the communication required between departments for appropriate administering of financial aid, and the number of enrolled students receiving financial aid. Cause: The financial aid department continues to adjust staffing but is still in the process of training new staff. Effect: Noncompliance with a number of Title IV regulations. Questioned costs as indicated in the following findings. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College implement additional training tools for the financial aid office, or consider outsourcing financial aid functions such as packaging, disbursing, reconciliations, etc. to a Title IV third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Satisfactory Academic Progress Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College was not adequately assessing Satisfactory Academic Progress (SAP), which resulted in financial aid being awarded to ineligible students. Criteria: 34 CFR 668.34(c) Questioned Costs: $25,530 Context: Out of 39 students tested for meeting SAP, there were 2 students who did not have an approval appeal on file to reinstate eligibility; therefore $9,530 of Pell and $16,000 of Federal Direct Loans were ineligible disbursements. Cause: This was an oversight by the College. Effect: Ineligible students were awarded federal aid. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College ensure there are reviews occurring at the end of each semester as indicated in the SAP policy. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

ISIR Comment Resolution Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not adequately resolve required ISIR Comment codes to determine student eligibility for federal aid. Criteria: 34 CFR 668.32 Questioned Costs: $12,745 Context: Out of 39 students tested, 2 students had ISIR comment codes for which resolution was required that were not adequately addressed before the disbursement of aid. The first student's code (359) was for Unusual Enrollment History, and the second student's code was for Aggregate Loan Limits. This resulted in over awarding $4,445 of Pell and $8,300 in Federal Direct Loans. Cause: This was an oversight by the College. Effect: Federal aid is impacted directly by the results of ISIR comment codes requiring resolution. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College respond adequately to all ISIR comment codes requiring resolution to ensure student eligibility before the disbursement of federal aid. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: The 39 students tested for proper NSLDS enrollment status did not have their enrollment updated for the year under audit. Cause: Due to turnover in the financial aid office, NSLDS was not updated accurately for the 22-23 year. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Enrollment Reporting to NSLDS Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 and 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Criteria: 34 CFR 690.83(b) and 34 CFR 685.309 Questioned Costs: $0 Context: The 39 students tested for proper NSLDS enrollment status did not have their enrollment updated for the year under audit. Cause: Due to turnover in the financial aid office, NSLDS was not updated accurately for the 22-23 year. Effect: Inaccurate reporting can impact a student's loan grace period in school deferment eligibility, beginning loan repayments, appropriate interest charges, etc. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend that the College put a system in place to ensure that enrollment is reported timely and accurately. Additionally, we recommend that the College complete spot checks of NSLDS enrollment statuses throughout the year. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Need Analysis Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students were not initially appropriately awarded federal loans based on need. Criteria: 34 CFR 685.200(a) Questioned Costs: $20,719 Context: Out of 39 students tested, 6 students were not awarded aid appropriately based on need analysis. Three students were awarded federal direct subsidized loans in excess of cost of attendance, resulting in a total of $6,728 over awarded to them. Another student was enrolled less than half time, making them eligible for federal direct loans. This resulted an over award of $5,500 in subsidized loans and $6,000 in unsubsidized loans. Additionally, one student declined their loans however they were still disbursed leading to an over award of $2,491 in subsidized loans. Lastly, the remaining student accepted their loans but these were not disbursed, resulting in an under award of $950 subsidized loans and $6,000 unsubsidized loans. Cause: The College identified that there were scholarships in the student information system that were not set up to count towards cost of attendance and need analysis calculations. There were also oversights by the College for students who accepted or declined their loans. Effect: Students received federal loans for which they were not eligible. Identification as repeat finding, if applicable: 2022-007 Recommendation: We recommend the College ensure that all scholarships are marked as estimated financial assistance and an awarding check is done accurately before disbursement is completed for the student. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect Pell Calculations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Students at the College were not properly awarded Pell. Criteria: 34 CFR 690.63(b) Questioned Costs: $1,877 Context: Out of 39 students tested for Pell grant eligibility, 6 were not properly awarded Pell awards. Four of these students had an incorrect Pell calculation performed, resulting in $1,877 of Pell over awarded, and one under award of $400. Another 2 students were not paid for classes they began attendance in, leading to a total of $7,307 under awarded to them. Cause: These were oversights by the College. Effect: There was an incorrect amount of Pell paid to these students. Identification as repeat finding, if applicable: 2022-005. Recommendation: We recommend a process be implemented to verify Pell is correctly awarded before disbursements are made. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Two students of 39 tested had COD loan disbursement date errors ranging from 25-153 days, both in the Fall and Spring terms. One student out of 39 tested had COD Pell disbursement date error of 15 days. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend the College implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Common Origination and Disbursement (COD) Reporting and Reconciliations Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The dates and amounts that Pell and Federal Direct Loans (FDL) awards were posted to student accounts did not always agree to disbursement records reported to Common Origination and Disbursement (COD). Reconciliations between COD and disbursements to student accounts were not performed regularly. Criteria: 34 CFR 668.164, 34 CFR 685.300(b)(5), 34 CFR 685.301(a)(2) and 34 CFR 690.83 Questioned Costs: $0 Context: Two students of 39 tested had COD loan disbursement date errors ranging from 25-153 days, both in the Fall and Spring terms. One student out of 39 tested had COD Pell disbursement date error of 15 days. Cause: Reconciliations of College records to COD were not completed regularly so the errors between the two systems were not identified in a timely manner. Effect: Inaccurate reporting of disbursements to COD can impact accrued interest for FDL as well as the monitoring of Pell lifetime limits and FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend the College implement procedures to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Return of Title IV (R2T4) Unearned Funds Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Unearned Title IV aid was not returned timely. Criteria: 34 CFR 668.21, 34 CFR 668.22 Questioned Costs: $11,039 Context: The College was unable to provide support that students began attendance for 4 students with no passing grades in a term tested as unofficial withdraws. Of these 4 students, 2 students were enrolled only in distance education courses. The Title IV aid disbursed should have all been returned to the Department of Education. Cause: The College does not have a process to monitor students for academic activity in distance education courses. The College does not have a process to monitor students with federal aid disbursed for unofficial withdrawals. Effect: Noncompliance with R2T4 regulations regarding withdrawals. Noncompliance with the requirement to determine a student has begun attendance in all courses for which Title IV aid is disbursed. Noncompliance with the requirement for distance education courses to have evidence of academic engagement to establish attendance in those courses. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend a 0-credit report be run at the end of each semester to ensure all withdrawals are followed up on so that R2T4s are completed timely when required. We further recommend a process be implemented to track student attendance in courses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, 84.033, and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $0 Context: The College has not sufficiently documented its security risk assessment and safeguards, including general threats, multi-factor authentication on systems containing personally identifiable information (PII), or continuous monitoring, such as penetration testing and vulnerability scanning. Additionally, the College has not fully implemented sufficient vendor management policies and reviews, implemented an incident response plan, or provided a written, annual report to the board. Cause: The College has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The College has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable. Recommendation: We recommend the College allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Cash Management Significant Deficiency DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063 and 84.033 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College initiated three Federal Direct Loan and four Pell drawdowns from G5 for amounts greater than what had been disbursed to students. Additionally, Federal Work Study funds were drawn down and not disbursed within the required timeframe. Criteria: 34 CFR 668.166(a) Questioned Costs: $0 Context: During our audit, it was noted that 3 Federal Direct Loan drawdowns out of 5 tested and 4 Pell drawdowns out of 4 tested did not properly tie to student disbursement rosters related to the draw. Additionally, it was noted that the College drew down all Federal Work Study funds at the beginning of the fall semester before any of these funds were earned by the students. Cause: Turnover and staffing challenges in the financial aid office. Additionally, reconciliations were not being performed throughout the year. See finding 2023-010. Effect: The College appears to have excess cash on hand at certain times throughout the year, however at the end of the financial aid year they had disbursed more than they had drawn. Federal Work Study funds were disbursed by the end of the fall semester. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend that the College review its reconciliation process and implement controls to ensure that funding is drawn and disbursed within three business days of receipt. We also recommend that the College review student disbursement reports generated to determine drawdown amounts before making draws from G5. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.