2022-003 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. Questioned Costs: None Context: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat findings: 2021-005 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-006 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Assistance Listing No. 84.063, 84.268 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 ? NSLDS tracks how many students, included on a school?s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2). Condition: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Questioned Costs: None Context: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-008 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-008 Inadequate Schedule of Federal Expenditures Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: CFR ?200.510(b) of the Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total federal awards expended as determined in accordance with ?200.502 of the Uniform Guidance, ?Basis for Determining Federal Awards Expended. Condition: Though the College provided a Schedule of Federal Expenditures, the College did not have the controls in place to provide a Schedule of Federal Expenditures timely. Questioned Costs: None Context: The College did not have the controls in place to provide a Schedule of Federal Expenditures in a timely manner. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: An incorrect Schedule of Federal Expenditures can delay an audit beyond the reporting deadline and cause unnecessary audit costs. Also, the delay could cause the College not to be in compliance with the DCF submission. Repeat findings: 2021-011 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-009 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.268 Federal Award Identification Number and Year: P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Regulations (34 CFR 668.164(i)(2)) Early Disbursements. An institution may not: (1) Make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5). This restriction does not apply if the institution is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A) or (B); or (2) Compensate a student employed under the FWS program until the student earns that compensation by performing work, as provided in 34 CFR 675.16(a)(5). Condition: During our testing, Of the sixty (60) students tested for eligibility, one (1) student, who was a first-time borrower, was disbursed aid before the 30-day requirement. Questioned Costs: None Context: During our testing, Of the sixty (60) students tested for eligibility, one (1) student, who was a first-time borrower, was disbursed aid before the 30-day requirement. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Failure to properly disburse Title IV funds based on requirements in accordance with federal regulations may result in noncompliance with regulations. Repeat findings: N/A Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-003 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. Questioned Costs: None Context: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat findings: 2021-005 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-004 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Award Identification Number and Year: P063P218567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Regulations (34 CFR 690.79) Liability for and recovery of Federal Pell Grant overpayments. A student is liable for any Federal Pell Grant overpayment made to him or her except for the following 2 situations: (1) The institution is liable for a Federal Pell Grant overpayment if the overpayment occurred because the institution failed to follow the procedures set forth in this part or 34 CFR Part 668. The institution must restore an amount equal to the overpayment to its Federal Pell Grant account; or (2) A student is not liable for, and the institution is not required to attempt recovery of or refer to the Secretary, a Federal Pell Grant overpayment if the amount of the overpayment is less than $25 and is not a remaining balance. Condition: During our testing, of the sixty (60) students tested for eligibility, three (3) students had more aid awarded and disbursed than what was earned. Questioned Costs: $3,757 Context: During our testing, of the sixty (60) students tested for eligibility, three (3) students had more aid awarded and disbursed than what was earned. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat findings: N/A Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-006 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Assistance Listing No. 84.063, 84.268 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 ? NSLDS tracks how many students, included on a school?s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2). Condition: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Questioned Costs: None Context: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-008 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-008 Inadequate Schedule of Federal Expenditures Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: CFR ?200.510(b) of the Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total federal awards expended as determined in accordance with ?200.502 of the Uniform Guidance, ?Basis for Determining Federal Awards Expended. Condition: Though the College provided a Schedule of Federal Expenditures, the College did not have the controls in place to provide a Schedule of Federal Expenditures timely. Questioned Costs: None Context: The College did not have the controls in place to provide a Schedule of Federal Expenditures in a timely manner. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: An incorrect Schedule of Federal Expenditures can delay an audit beyond the reporting deadline and cause unnecessary audit costs. Also, the delay could cause the College not to be in compliance with the DCF submission. Repeat findings: 2021-011 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-003 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. Questioned Costs: None Context: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat findings: 2021-005 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-006 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Assistance Listing No. 84.063, 84.268 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 ? NSLDS tracks how many students, included on a school?s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2). Condition: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Questioned Costs: None Context: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-008 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-008 Inadequate Schedule of Federal Expenditures Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: CFR ?200.510(b) of the Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total federal awards expended as determined in accordance with ?200.502 of the Uniform Guidance, ?Basis for Determining Federal Awards Expended. Condition: Though the College provided a Schedule of Federal Expenditures, the College did not have the controls in place to provide a Schedule of Federal Expenditures timely. Questioned Costs: None Context: The College did not have the controls in place to provide a Schedule of Federal Expenditures in a timely manner. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: An incorrect Schedule of Federal Expenditures can delay an audit beyond the reporting deadline and cause unnecessary audit costs. Also, the delay could cause the College not to be in compliance with the DCF submission. Repeat findings: 2021-011 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-009 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.268 Federal Award Identification Number and Year: P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Regulations (34 CFR 668.164(i)(2)) Early Disbursements. An institution may not: (1) Make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5). This restriction does not apply if the institution is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A) or (B); or (2) Compensate a student employed under the FWS program until the student earns that compensation by performing work, as provided in 34 CFR 675.16(a)(5). Condition: During our testing, Of the sixty (60) students tested for eligibility, one (1) student, who was a first-time borrower, was disbursed aid before the 30-day requirement. Questioned Costs: None Context: During our testing, Of the sixty (60) students tested for eligibility, one (1) student, who was a first-time borrower, was disbursed aid before the 30-day requirement. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Failure to properly disburse Title IV funds based on requirements in accordance with federal regulations may result in noncompliance with regulations. Repeat findings: N/A Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-003 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The DoE requires institution to report the disbursement dates and amounts to the COD system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. Questioned Costs: None Context: During our testing, of the 60 disbursements tested, twenty four (24) had incorrect disbursement dates to the COD system. While performing audit procedures, it was noted that information was incorrectly reported to the COD and was not updated within the 15-day reporting time frame. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat findings: 2021-005 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-004 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Federal Award Identification Number and Year: P063P218567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Regulations (34 CFR 690.79) Liability for and recovery of Federal Pell Grant overpayments. A student is liable for any Federal Pell Grant overpayment made to him or her except for the following 2 situations: (1) The institution is liable for a Federal Pell Grant overpayment if the overpayment occurred because the institution failed to follow the procedures set forth in this part or 34 CFR Part 668. The institution must restore an amount equal to the overpayment to its Federal Pell Grant account; or (2) A student is not liable for, and the institution is not required to attempt recovery of or refer to the Secretary, a Federal Pell Grant overpayment if the amount of the overpayment is less than $25 and is not a remaining balance. Condition: During our testing, of the sixty (60) students tested for eligibility, three (3) students had more aid awarded and disbursed than what was earned. Questioned Costs: $3,757 Context: During our testing, of the sixty (60) students tested for eligibility, three (3) students had more aid awarded and disbursed than what was earned. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat findings: N/A Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-006 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Assistance Listing No. 84.063, 84.268 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: Per the NSLDS reporting guide: The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. Also, per the NSLDS reporting guide (section 2.4.1 ? NSLDS tracks how many students, included on a school?s Roster file, were certified with Program Level information and whether a school has reported programs with a 2020 CIP Year (Enrollment Reporting Statistics). This information is used to determine whether a school is complying with applicable regulations and guidance. Schools must ensure that all students enrolled in programs are reported with programs, as well as report a status for all programs on their Roster. Schools found to be non-compliant with NSLDS enrollment reporting requirements will receive a series of warning letters before being referred for compliance action. Additionally, having the correct CIP and program start date, allows NSLDS to determine if a borrower will lose subsidy (2.4.2). Condition: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Questioned Costs: None Context: Out of the sample of eight students, we noted four (4) students whose program beginning dates that were reported to NSLDS did not agree to the institutions records. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-008 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-008 Inadequate Schedule of Federal Expenditures Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: CFR ?200.510(b) of the Uniform Guidance requires the auditee to prepare a SEFA for the period covered by the auditee?s financial statements which must include the total federal awards expended as determined in accordance with ?200.502 of the Uniform Guidance, ?Basis for Determining Federal Awards Expended. Condition: Though the College provided a Schedule of Federal Expenditures, the College did not have the controls in place to provide a Schedule of Federal Expenditures timely. Questioned Costs: None Context: The College did not have the controls in place to provide a Schedule of Federal Expenditures in a timely manner. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: An incorrect Schedule of Federal Expenditures can delay an audit beyond the reporting deadline and cause unnecessary audit costs. Also, the delay could cause the College not to be in compliance with the DCF submission. Repeat findings: 2021-011 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.