Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: When calculating return to title IV (R2T4), percent completed is calculated by dividing total number of calendar days by amount attended, per 34 CFR 668.22(f)(2)(i), the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations.
Questioned costs: None
Context: During our testing of 10 R2T4 calculations, we identified that 8 had mechanically incorrect calculation by using the incorrect number of scheduled break days.
Cause: The College was using the incorrect number of scheduled break days for Fall Semester.
Effect: The College could return incorrect amounts based off of their calculations, which could effect
student repayment amounts based off of amount earned.
Repeat Finding: Yes (2023-001)
Recommendation: We recommend that the College review policies and procedures related to R2T4
calculations to ensure calculations are performed correctly.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
Additionally, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days.
Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS).
Questioned costs: None.
Context: During our testing of 40 students, we identified 9 students had the incorrect effective date, 4 students were reported past the 60-day reporting timeframe, and 1 student did not have matching status change for Campus and Program enrollment.
Cause: The College didn't have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner.
Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans.
Repeat Finding: No.
Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.
Federal Agency: US Department of Education
Federal Program Name: Student Financial Assistance Cluster
Assistance Listing Number: 84.063, 84.007, & 84.033
Federal Award Identification Number and Year: P063P231353-2024, P063Q231353-2024,
P033A231190-2024, & P007A231190-2024
Award Period: July 1, 2023 to June 30, 2024
Type of Finding:
• Significant Deficiency in Internal Control over Compliance
• Other Matters
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)).
Condition: During our testing of the College’s information technology systems, we noted the Written Information Security Program did not include all of the required elements.
Questioned costs: None.
Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student assistance programs.
Cause: The College is in process of updating written policies and procedures to address all of the required elements.
Effect: Student personal information could be vulnerable.
Repeat Finding: No.
Recommendation: We recommend the College work to update the written information security program to ensure compliance with all of the required elements.
Views of responsible officials: Management agrees with this finding.