Audit 5338

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-001 Enrollment Reporting Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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: We noted, during our testing, that five out of 40 students tested whose enrollment status was not updated to graduate to NSLDS. Six out of 40 students tested enrollment status was reported timely. We also noted that 30 of the 40 students tested did not have effective dates in NLSDS compared to the institutions’ records. Lastly, for three of the 40 students tested, the program effective date did not agree in NSLDS to the institutions’ records. Questioned Costs: None Cause: The College’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause overawarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Gramm-Leach-Bliley Act Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and 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 prepare a formal 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 College has hired a consultant to help with and enhance the implementation of the updated Gramm-Leach-Bliley Act requirements and that didn’t occur until late in the 2023 fiscal year. Effect: The student personal information could potentially be vulnerable. Repeat Finding: No Recommendation: We recommend the College work with their consulting firm to review their documentation and ensure that there are documented safeguards for identified risks and the required documentation and practices are implemented. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Views of responsible officials: There is no disagreement with the audit finding.