FAC Explorer

Audit 3665

FY End
2023-06-30
Total Expended
$2.27M
Findings
22
Programs
7
Organization: Dallas Christian College (TX)
Year: 2023 Accepted: 2023-11-19
Auditor: Capincrouse LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
2112 2023-001 - Yes N
2113 2023-001 - Yes N
2114 2023-001 - Yes N
2115 2023-001 - Yes N
2116 2023-002 - Yes N
2117 2023-003 - - N
2118 2023-003 - - N
2119 2023-003 - - N
2120 2023-003 - - N
2121 2023-003 - - N
2122 2023-004 - Yes N
578554 2023-001 - Yes N
578555 2023-001 - Yes N
578556 2023-001 - Yes N
578557 2023-001 - Yes N
578558 2023-002 - Yes N
578559 2023-003 - - N
578560 2023-003 - - N
578561 2023-003 - - N
578562 2023-003 - - N
578563 2023-003 - - N
578564 2023-004 - Yes N

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $1.59M Yes 4
84.063 Federal Pell Grant Program $611,435 Yes 2
84.425 Covid-19 Education Stabilization Fund Heerf - Institutional Portion $25,523 - 0
84.033 Federal Work-Study Program $23,199 Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $14,625 Yes 2
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772 Yes 2
84.425 Covid-19 Education Stabilization Fund Heerf - Strengthening Institutions $1,169 - 0

Contacts

Name Title Type
HWTQJKWFKJC9 Christopher Winslow Auditee
9722413371 Junice Jones, CPA Auditor
No contacts on file

Notes to SEFA

Title: RELATIONSHIP TO FINANCIAL STATEMENTS Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Dallas Christian College (College) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate See the Notes to the SEFA for chart/table
Title: SUBRECIPIENTS, NON-CASH ASSISTANCE, FEDERAL INSURANCE, LOANS, AND LOAN GUARANTEES Accounting Policies: The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activity of Dallas Christian College (College) under programs of the federal government for the year ending June 30, 2023. The information in the schedule is presented in accordance with the requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Therefore, some amounts presented in the schedule may differ from amounts presented in, or used in the preparation of, the basic financial statements. Expenditures in the schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. If the College is required to match certain federal assistance, as defined by the grant agreements, no such matching has been included as expenditures in the schedule. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate The College did not provide any federal funds to subrecipients nor did they receive any federal non-cash assistance, insurance, loans, or loan guarantees.

Finding Details

Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) correctly for one student. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 51 students tested, 1 student who withdrew after the fall semester was not reported as withdrawn. This was corrected during the audit process. Cause: This was an oversight. 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: Yes, 2022-002. Recommendation: We recommend the College put a system in place to ensure that students who leave after one semester are reported as withdrawn and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-004
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The FDL amounts posted to student account did not always agree to disbursement records reported to Common Origination and Disbursement (COD) for one student. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: One of 51 students tested, 1 student had a COD loan disbursement amount error of approximately $1,000 that was not caught in the monthly reconciliation. Cause: There was a miscommunication between the third party administrator and the College, and the monthly reconciliation process did not identify the discrepancy. Effect: Inaccurate FDL reporting can impact a student’s interest accumulating period based on the dates and amounts of the loan disbursement dates as well as the monitoring of FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Yes, see 2022-003. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts and that all dates and amounts be part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-001
Return of Title IV (R2T4) Calculations DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007 and 84.379 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: There was one incorrect calculation of returned funds for a student that withdrew during the term due to the incorrect calendar being used. Criteria: 34 CFR 668.22 Questioned Costs: $-0- Context: Out of 7 students, 1 students who withdrew during the audit period tested had incorrect funds returned. The student had $113 more of Pell funds returned than required. Cause: The College uses a third party administrator to assist in the R2T4 calculations, and an incorrect calendar was used for the student. Effect: Incorrect amount of unearned Title IV funds returned. Identification as repeat finding, if applicable: Yes, 2022-001. Recommendation: We recommend the College add a check for reviewing the appropriate calendar to be used for each student with the third party administrator. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-002
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The College did not report enrollment information to the National Student Loan Data System (NSLDS) correctly for one student. Criteria: 34 CFR 685.309 Questioned Costs: $-0- Context: Out of 51 students tested, 1 student who withdrew after the fall semester was not reported as withdrawn. This was corrected during the audit process. Cause: This was an oversight. 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: Yes, 2022-002. Recommendation: We recommend the College put a system in place to ensure that students who leave after one semester are reported as withdrawn and that the College is completing spot checks of enrollment statuses to NSLDS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-003
Gramm-Leach-Bliley Act (GLBA) Compliance 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 College did not sufficiently comply with the updated requirements of GLBA. Criteria: 16 CFR 314.4 Questioned Costs: $-0- Context: The College has not implemented multi-factor authentication (MFA) on all systems containing personally identifiable information (PII) and fully documented its vendor management program, including updates to the board on vendors that do not meet the College’s security requirements. Cause: The College has put forth significant effort to comply with the updated regulations. One system does not allow MFA natively, and the College is exploring options to improve its security related to this system. As part of this review, the College is working to vet all potential vendors related to this system's business functions and will be providing updates to the board. Effect: The College may have 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.
Finding 2023-004
Common Origination and Disbursement (COD) Reporting DEPARTMENT OF EDUCATION ALN #: 84.268 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The FDL amounts posted to student account did not always agree to disbursement records reported to Common Origination and Disbursement (COD) for one student. Criteria: 34 CFR 668.164(a) Questioned Costs: $-0- Context: One of 51 students tested, 1 student had a COD loan disbursement amount error of approximately $1,000 that was not caught in the monthly reconciliation. Cause: There was a miscommunication between the third party administrator and the College, and the monthly reconciliation process did not identify the discrepancy. Effect: Inaccurate FDL reporting can impact a student’s interest accumulating period based on the dates and amounts of the loan disbursement dates as well as the monitoring of FDL aggregate limits for subsidized and unsubsidized loans. Identification as repeat finding, if applicable: Yes, see 2022-003. Recommendation: We recommend that procedures be implemented to ensure that disbursement reporting to COD be reflective of the actual disbursement dates and amounts and that all dates and amounts be part of the monthly reconciliation process. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.