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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student?s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned costs: None. Context: During our testing we noted three out of forty-one students, from a statistically valid sample, were awarded less Pell than they were eligible for based on the 2021-22 Pell payment schedule. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to human error when entering student's Cost of Attendance. Effect: Students did not receive the full amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 180.300) requires that, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Condition: The College did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Context: During our testing, we noted three out of five vendors tested did not have proper documentation for suspension and debarment verification. Cause: There are no procedures in place to routinely assess suspension and debarment for multi-year contracts with vendors, and inadequate maintenance of evidence the procedure occurred when suspension and debarment are assessed. Effect: Failure to assess suspension and debarment could lead to the College working with unqualified vendors. Repeat Finding: Yes, 2021-007. Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student?s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned costs: None. Context: During our testing we noted three out of forty-one students, from a statistically valid sample, were awarded less Pell than they were eligible for based on the 2021-22 Pell payment schedule. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to human error when entering student's Cost of Attendance. Effect: Students did not receive the full amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 180.300) requires that, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Condition: The College did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Context: During our testing, we noted three out of five vendors tested did not have proper documentation for suspension and debarment verification. Cause: There are no procedures in place to routinely assess suspension and debarment for multi-year contracts with vendors, and inadequate maintenance of evidence the procedure occurred when suspension and debarment are assessed. Effect: Failure to assess suspension and debarment could lead to the College working with unqualified vendors. Repeat Finding: Yes, 2021-007. Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.