2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-005 Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted the reports were not properly reviewed prior to submission. Furthermore, Tabor College did not keep individual student reports posted to the website for each quarter as they continuously updated it. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have controls in place to review the reports to ensure that they posted the reporting timely and accurately. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the College establish a system to track due dates of reports to ensure timely submission. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where institutions should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned Costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was nonstudent financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022-005 Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted the reports were not properly reviewed prior to submission. Furthermore, Tabor College did not keep individual student reports posted to the website for each quarter as they continuously updated it. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have controls in place to review the reports to ensure that they posted the reporting timely and accurately. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the College establish a system to track due dates of reports to ensure timely submission. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where institutions should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned Costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was nonstudent financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-002 Eligibility and Certification Approval Report (ECAR) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.25(e) states that an institution must notify the Department of Education by way of the ECAR within 10 days of a change in position of an official at the College and changes in third party servicers. Condition: During our testing, we noted the VP of Finance had a change in position and it was not updated within 10 days. Furthermore, CliftonLarsonAllen was still listed as a third party services which should have been removed. Lastly, National Student Clearinghouse (NSC) should have been added as a third party servicer. Questioned costs: None Context: During our testing, we noted the VP of Finance had a change of position and it was not updated within 10 days. The third party servicer page was also not update to properly reflect the College?s third party servicers. Cause: The VP of Finance left during 2022 and there was no replacement for a few months. The removal of the position was not done to add a temporary VP of Finance nor did they update the VP of Finance once the permanent replacement began. Effect: The College is not in compliance with Department of Education requirements that state the ECAR must have accurately reported information. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-003 Return of Title IV (R2T4) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Condition: During our testing, we noted two out of the six individuals tested had used an incorrect percentage of days attended causing the College to incorrectly calculated the return of Title IV funds. Questioned Costs: None Context: During our testing, we noted the College had used a 7-day break during the spring semester instead of using a 9-day break causing impact on the calculation on percent of aid earned and the amount of Title IV aid refunded. Cause: The College?s return of Title IV funds template was not including the correct amount of days during a 5-day break during their spring semester thus students? percentage of days attended was miscalculated. Effect: The College is not completing accurate return of Title IV funds calculations as defined by the regulations. Repeat Finding: No Recommendation: We recommend the College review the return of Title IV funds requirements and implement procedures to ensure the return of Title IV funds calculations are using the correct number of break days and are accurately completed. Views of responsible officials: There is no disagreement with the audit finding.
2022-004 National Student Loan Data System (NSLDS) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to 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 that 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. 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. Condition: During our testing, we noted two out of 12 student's effective enrollment date per the institution did not match the student's effective date reported to NSLDS. Additionally, one out of the 12 student's change in status was not reported to NSLDS within 30 days (or 60 days) after school determined the change. One out of the 12 student's enrollment was not certified every 60 days. Lastly, The College had two instances where error records were not corrected and resubmitted within 10 days. Questioned Costs: None Context: We noted discrepancies in the period it took to report changes in enrollment statuses to NSLDS and data reported in NSLDS is supported by the College?s records. Cause: The College?s processes and controls did not ensure that student status changes and effective dates were properly reported to NSLDS. Effect: The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.
2022-007 Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: Various Award Period: July 1, 2021 to June 30, 2022 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 financial 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 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 did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (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 systems failures and document safeguards for identified risks. Cause: The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.
2022-005 Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted the reports were not properly reviewed prior to submission. Furthermore, Tabor College did not keep individual student reports posted to the website for each quarter as they continuously updated it. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have controls in place to review the reports to ensure that they posted the reporting timely and accurately. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the College establish a system to track due dates of reports to ensure timely submission. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where institutions should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned Costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was nonstudent financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.
2022-005 Higher Education Emergency Relief Funds (HEERF) Reporting Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, we noted the reports were not properly reviewed prior to submission. Furthermore, Tabor College did not keep individual student reports posted to the website for each quarter as they continuously updated it. Questioned Costs: None Context: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. Cause: The College did not have controls in place to review the reports to ensure that they posted the reporting timely and accurately. Effect: There was inaccurate reporting on the College?s website. Repeat Finding: No Recommendation: We recommend the College establish a system to track due dates of reports to ensure timely submission. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where institutions should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned Costs: None Context: The College did have appropriate documentation that met the procurement, and suspension and debarment federal requirements. However, the written policies were not in place at time of procurement or entering into contracts with vendors. Cause: The College was unaware of this federal requirement since it is their first federal grant that was nonstudent financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.