Audit 404302

2025–002: National Student Loan Database System (NSLDS) Reporting Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program; Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: P063P242088; P268K252088 - 2025 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. ED requires the College to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None. Context: During our testing, we noted the following: • 4 students out of a sample of 40 students tested were not reported to the campus-level record in the NSLDS in a timely manner. • 1 student out of a sample of 40 students had an enrollment effective date in the program-level records that did not match what was reflected in the College’s records and the campus-level record in the NSLDS. Cause: Management's procedures to report accurate and timely information to the NSLDS were not operating effectively. Effect: Inaccurate reporting to the NSLDS can impact when students enter repayment periods or affect their interest rates. Repeat Finding: Yes, 2024-004. Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2025-003: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Federal Work Study Program Assistance Listing Number: 84.007, 84.063, 84.268, Federal Award Identification Number and Year: P063P242088; P007A243557; P268K252088; P033A243557 - 2025 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Condition: Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools 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 financial aid programs. Questioned Costs: None Context: During our audit procedures, it was noted that the College had not performed penetration testing and did not have an IT risk assessment performed.. Cause: The College did not perform penetration testing and did not have an IT risk assessment performed as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes, 2024-005. Recommendation: The College should develop and implement annual penetration testing and perform IT risk assessment. Views of Responsible Officials: There is no disagreement with the audit finding.