2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2023 -005 Approval Of Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 - Child Nutrition Cluster, 21.027 - American Rescue Plan Act And 84.425/84.425C/84.425D/84.425U/84.425W - Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View Of Responsible Officials: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #421030129 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital selected option II to calculate lost revenue, which consists of a comparison of actual results during the period of availability to the approved budget. The Hospital did not have a budget for the entire reporting period that was approved prior to March 27, 2020. For the periods that the client did not have an approved budget, $0 was entered for net patient revenues even though there were patient revenues for this period. Cause: The Hospital did have an approved budget prior to March 27, 2020 for fiscal year 2020, but the approved budget did not cover the entire period of availability. Effect: The reporting to HHS for Period 4 was considered incorrect. The Hospital did not have a budget approved prior to March 27, 2020 for the entire period of availability. The Medical Center reported $0 for quarter 3 and 4 of 2021 and quarters 1, 2, 3 and 4 of 2022. Questioned Costs: None. The Hospital claimed expenses for all Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution amounts in Period 4, so did not use lost revenue to support any of these. Context: Key line items were tested on the Period 4 HHS report. Repeat Finding from Prior Years: No Recommendation: We recommend the Hospital implement procedures to ensure the lost revenue calculation claimed meets the requirements of the federal program. Views of Responsible Officials: Management agrees with the finding.
Department of Health and Human Services Federal Assistance Listing #93.498 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 4 TIN #421030129 Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Reporting Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Hospital did not retain evidence of the review and approval of the expenditure listing and lost revenue calculation by a separate individual outside of the preparer. In addition, The Hospital’s special report submitted to the Department of Health and Human Services for Period 4 TIN #421030129 did not have evidence that it was reviewed and approved by a separate individual outside of the preparer. Cause: The Hospital did not have an internal control process in place to ensure a secondary review and approval of the expenditure listing, lost revenue calculation, and report submitted to the Department of Health and Human Services for Period 4 was documented. Effect: Without a secondary review and approval, there is a possibility that ineligible expenditures or lost revenue may be claimed under the program and the special report might not be accurately completed. Questioned Costs: None reported. Context: A nonstatistical sample of 41 expenditures were selected for testing, which accounted for $971,367 of $1,077,594 direct program expenditures. The entire lost revenue calculation was tested, and key line items were tested on the Period 4 HHS report. Repeat Finding from Prior Years: Yes Recommendation: We recommend the Hospital implement a control process which includes a secondary review and approval of the expenditure listing and lost revenue calculation and a secondary review and approval of the required reports to be submitted to the federal agency be documented. Views of Responsible Officials: Management agrees with the finding.
2023 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the District to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the District’s information technology, we noted the District did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: 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. Cause: The District has continued to make progress in updating the District’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the District work to update the written security program to ensure compliance with all the standards. Views of responsible officials: The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.
2023 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the District to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the District’s information technology, we noted the District did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: 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. Cause: The District has continued to make progress in updating the District’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the District work to update the written security program to ensure compliance with all the standards. Views of responsible officials: The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.
2023 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the District to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the District’s information technology, we noted the District did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: 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. Cause: The District has continued to make progress in updating the District’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the District work to update the written security program to ensure compliance with all the standards. Views of responsible officials: The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.
2023 – 001 Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program) Federal Award Identification Number and Year: N/A; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the District to establish and maintain effective internal controls over Federal awards. Condition: During our testing of the District’s information technology, we noted the District did not maintain a comprehensive written security program that included the minimum required elements. Questioned costs: None Context: 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. Cause: The District has continued to make progress in updating the District’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Effect: The student personal information could be vulnerable. Repeat finding: No Recommendation: We recommend the District work to update the written security program to ensure compliance with all the standards. Views of responsible officials: The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.
2023 – 002 Federal Agency: U.S. Department of Commerce Federal Program Name: Economic Adjustment Assistance Assistance Listing Number: 11.307 Federal Award Identification Number and Year: ED22HDQ3070089; 2022-2023 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Other Matters Criteria or specific requirement: In accordance with the Federal Funding Accountability and Transparency Act of 2006 (FFATA), prime recipients of a federal grant must report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds on a public-facing, OMB-designated, governmentwide website. The report must be submitted by the end of the following month during which the prime recipient makes the subaward (2 CFR 170). The Code of Federal Regulations 2 CFR 200.303 requires the District to establish and maintain effective internal controls over Federal awards. Condition: During our testing of FFATA reporting requirements for 5 subrecipients of the Economic Adjustment Assistance program, the District failed to report information required by the FFATA for the subawards granted to each of these subrecipients. Questioned costs: None Context: FFATA requires the District to report certain information related to awards made to subrecipients greater than or equal to $30,000. Amounts passed through to all subrecipients under the Economic Adjustment Assistance program, also the total amount of subrecipient payments selected for testing totaled $226,412 during the year ended June 30, 2023. Cause: The District’s processes and controls did not ensure that FFATA requirements were met. Effect: Failure to identify awards subject to FFATA and to report subawards in accordance with FFATA results in noncompliance with federal requirements. Repeat finding: No Recommendation: We recommend the District establish procedures to identify awards subject to FFATA reporting requirements and report required subaward information in accordance with FFATA. Views of responsible officials: A procedure has been established and in place for future awards involving sub-recipients. The College closely monitors grant activity to ensure compliance with underlying grant provisions and notes that there is no financial exposure to the College or the granting agency.
Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund – Higher Educational Emergency Relief Fund Assistance Listing Number: 84.425E – COVID-19 - HEERF – Student Aid Portion 84.425F – COVID-19 - HEERF – Institutional Portion Federal Award Identification Number and Year: P425E202061 – 2021, P425F200625 – 2021 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not follow requirements for timely reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted one of four quarterly reports tested was not published within 10 days after the calendar quarter. Cause: The College did not follow procedures in place to ensure reports were published timely. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely HEERF reporting. Repeat Finding: Yes. Prior year finding 2022-001 Recommendation: We recommend the College review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund – Higher Educational Emergency Relief Fund Assistance Listing Number: 84.425E – COVID-19 - HEERF – Student Aid Portion 84.425F – COVID-19 - HEERF – Institutional Portion Federal Award Identification Number and Year: P425E202061 – 2021, P425F200625 – 2021 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not follow requirements for timely reporting for the Quarterly Student and Institutional program. Questioned Costs: None Context: During our testing of the reporting process, we noted one of four quarterly reports tested was not published within 10 days after the calendar quarter. Cause: The College did not follow procedures in place to ensure reports were published timely. Effect: The College was not in compliance with the U.S. Department of Education (ED) regulations for timely HEERF reporting. Repeat Finding: Yes. Prior year finding 2022-001 Recommendation: We recommend the College review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: P268K220355 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of the submission of disbursement records to COD, we noted the disbursement dates on COD were different than the disbursement date per the College’s records. Questioned Costs: None Context: During our testing of the submission of disbursements records to COD, we noted the disbursement date for 7 of 29 direct loan disbursements tested were different by one day between COD and the College’s records. Cause: The College reported the disbursement date to COD and the disbursements were not posted to student accounts until the next day. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes. Prior year finding 2022-003 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported timely. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Loans Federal Award Identification Number and Year: P268K220355 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College over paid federal direct loans. Questioned Costs: None Context: During our eligibility testing of 40 students, we noted one student had a subsidized loan over payment due to reaching their subsidized aggregate loan limit. Cause: When doing the award packaging for this student, the College did not adjust award amounts based on the student’s subsidized aggregate loan limit activity. Effect: The institution paid this student an amount of subsidized loans that was above the subsidized aggregate loan limit. Repeat Finding: No. Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not update student status changes and enrollment effective dates correctly or timely. Questioned Costs: None Context: During our sample test of 19 students, we noted: 17 students’ enrollment status on NSLDS differed from the College’s records. 17 students’ status change was not reported timely. 16 students’ enrollment effective dates on NSLDS differed from the College’s records. The enrollment was not certified at least every 60 days for 19 students. Cause: The College did not have proper procedures in place to verify that student and enrollment status changes in NSLDS matched the institutions records, nor were status changes updated in a timely manner. 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. See prior year finding 2022-006 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not update student status changes and enrollment effective dates correctly or timely. Questioned Costs: None Context: During our sample test of 19 students, we noted: 17 students’ enrollment status on NSLDS differed from the College’s records. 17 students’ status change was not reported timely. 16 students’ enrollment effective dates on NSLDS differed from the College’s records. The enrollment was not certified at least every 60 days for 19 students. Cause: The College did not have proper procedures in place to verify that student and enrollment status changes in NSLDS matched the institutions records, nor were status changes updated in a timely manner. 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. See prior year finding 2022-006 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not update student status changes and enrollment effective dates correctly or timely. Questioned Costs: None Context: During our sample test of 19 students, we noted: 17 students’ enrollment status on NSLDS differed from the College’s records. 17 students’ status change was not reported timely. 16 students’ enrollment effective dates on NSLDS differed from the College’s records. The enrollment was not certified at least every 60 days for 19 students. Cause: The College did not have proper procedures in place to verify that student and enrollment status changes in NSLDS matched the institutions records, nor were status changes updated in a timely manner. 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. See prior year finding 2022-006 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not update student status changes and enrollment effective dates correctly or timely. Questioned Costs: None Context: During our sample test of 19 students, we noted: 17 students’ enrollment status on NSLDS differed from the College’s records. 17 students’ status change was not reported timely. 16 students’ enrollment effective dates on NSLDS differed from the College’s records. The enrollment was not certified at least every 60 days for 19 students. Cause: The College did not have proper procedures in place to verify that student and enrollment status changes in NSLDS matched the institutions records, nor were status changes updated in a timely manner. 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. See prior year finding 2022-006 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with GLBA in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that the College did not post required third-party servicer information to the website, nor did they provide the URL for the contract or cost information to ED. Questioned Costs: None Context: During our testing of 8 out of 32 students who have an account with the College’s third-party servicer, we noted the College did not post the third-party servicer's contract to the website, nor did they provide the URL for the contract to ED. Additionally, the required cost information was not on the website, nor was it updated within 60 days after the end of the award year, nor was the URL for the cost information provided to ED. Cause: The College did not have procedures in place to ensure that all requirements were being met. Effect: The College did not meet disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that the College did not post required third-party servicer information to the website, nor did they provide the URL for the contract or cost information to ED. Questioned Costs: None Context: During our testing of 8 out of 32 students who have an account with the College’s third-party servicer, we noted the College did not post the third-party servicer's contract to the website, nor did they provide the URL for the contract to ED. Additionally, the required cost information was not on the website, nor was it updated within 60 days after the end of the award year, nor was the URL for the cost information provided to ED. Cause: The College did not have procedures in place to ensure that all requirements were being met. Effect: The College did not meet disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that the College did not post required third-party servicer information to the website, nor did they provide the URL for the contract or cost information to ED. Questioned Costs: None Context: During our testing of 8 out of 32 students who have an account with the College’s third-party servicer, we noted the College did not post the third-party servicer's contract to the website, nor did they provide the URL for the contract to ED. Additionally, the required cost information was not on the website, nor was it updated within 60 days after the end of the award year, nor was the URL for the cost information provided to ED. Cause: The College did not have procedures in place to ensure that all requirements were being met. Effect: The College did not meet disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that the College did not post required third-party servicer information to the website, nor did they provide the URL for the contract or cost information to ED. Questioned Costs: None Context: During our testing of 8 out of 32 students who have an account with the College’s third-party servicer, we noted the College did not post the third-party servicer's contract to the website, nor did they provide the URL for the contract to ED. Additionally, the required cost information was not on the website, nor was it updated within 60 days after the end of the award year, nor was the URL for the cost information provided to ED. Cause: The College did not have procedures in place to ensure that all requirements were being met. Effect: The College did not meet disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.
Program - AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment Grant Number & Year - SLFRP0980, March 3, 2021, through December 31, 2024 Federal Grantor Agency - U.S. Department of the Treasury Criteria - Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2023) states the following, in relevant part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2023), which states the following: Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200. 2 CFR § 200.214 (January 1, 2023) states the following: Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR § 180.300 (January 1, 2023) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by: “(a) Checking SAM [System for Award Management] Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . . [entity].” A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities. Condition - Richardson County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented for vendor claims. We noted the County used Coronavirus State and Local Fiscal Recovery Funds to pay two vendors over $25,000, totaling $796,545, during the fiscal year ended June 30, 2023. The County failed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions. We reviewed SAM.gov, and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed. Repeat Finding - No Questioned Costs - None Statistical Sample - No Context - The following table provides details of the covered transactions noted: TABLE Cause - Lack of procedures and knowledge regarding suspension and debarment requirements. Effect - Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions. Recommendation - We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented. View of Officials - The County has put adopted new procedures within the Accounts Payable County Procedure Manual to actively verify vendors for eligibility utilizing the SAM exclusion database system. Procedure will include a printed copy of the search that will be signed and dated by the employee conducting the search. Document will be attached to the vendor file and the transaction that initiated the search.
2023-001: Student Eligibility and Awarding Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: P268K231182- 2023 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted 1 instance out of 40 students tested at the College where the Subsidized Stafford Loan awarded to the student was less than the maximum amount they were eligible for. An Unsubsidized Stafford Loan was then issued before the maximum subsidized loan amount was awarded. Questioned Costs: For the instance identified, the student was under awarded $1,000. Context: The District awarded $1,167,562 in Direct Loans during the year. Cause: Typographical error based on the department staff member using the values on the student’s loan request form. Effect: For the instance identified, the student was under awarded the unsubsidized portion of the Stafford Loan. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew. Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample. Questioned Costs: None. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew. Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample. Questioned Costs: None. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew. Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample. Questioned Costs: None. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-002: Return of Title IV Funds Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: According to 34 CFR Section 668.173 (b) and 2 CFR 200.303, the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (“FFEL”) lender no later than 45 days after the date of the institution’s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to postwithdrawal disbursements that are not disbursed to the student’s account, must be disbursed to the student no later than 180 days after the date of the institution’s determination that the student withdrew. Condition: The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 40 samples tested, which is a statistically valid sample. Questioned Costs: None. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The value of the sample tested was $4,811, and the portion of the unearned aid not returned timely was $353. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly. Questioned Costs: None. Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample. Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly. Questioned Costs: None. Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample. Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly. Questioned Costs: None. Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample. Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-003: NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 685.309(b), 2 CFR 200.303 and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of change in status not reported correctly. Questioned Costs: None. Context: Two exceptions were noted out of the 40 students tested, which is a statistically valid sample. Cause: The District’s internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe. Questioned Costs: Unknown. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population. Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations Effect: The District was unable to establish compliance with the Title IV regulation. Repeat Finding: Yes, see Finding 2022-005. Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe. Questioned Costs: Unknown. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population. Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations Effect: The District was unable to establish compliance with the Title IV regulation. Repeat Finding: Yes, see Finding 2022-005. Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe. Questioned Costs: Unknown. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population. Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations Effect: The District was unable to establish compliance with the Title IV regulation. Repeat Finding: Yes, see Finding 2022-005. Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-004: 240 Days Outstanding Check Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 668.164 states that an institution must return to the Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Department of Education no later than 240 days after the date it first issued the check. In addition, 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: Our audit identified checks were being cancelled within the 240-day timeframe, however the District was not able to provide support that the Department of Education’s Common Origination and Disbursement (COD) website was being updated within the allowable timeframe. Questioned Costs: Unknown. Context: The District disbursed $9,065,178 in Title IV awards during fiscal year 2022-23. The District provided a population of 1,076 checks outside the 240-day timeframe, totaling $958,167. However, we were unable to obtain actual questioned costs, as the population provided by the District included cancelled and reissued checks, resulting in duplication with the population. Cause: The District's existing procedures do not provide sufficient documentation to support compliance with Title IV regulations Effect: The District was unable to establish compliance with the Title IV regulation. Repeat Finding: Yes, see Finding 2022-005. Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers. Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements. Questioned Costs: None. Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act. Cause: The District's information security policy is still in draft form. Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers. Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements. Questioned Costs: None. Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act. Cause: The District's information security policy is still in draft form. Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Views of responsible officials: Management concurs with the finding and plans to correct the finding.
2023-005: Gramm-Leach-Bliley Act Compliance Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 16 CFR 314.3(a) and 2 CFR 200.303, Institutions are required to develop, implement and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include seven elements for institutions with fewer than 5,000 customers. Condition: During our testing, we noted the District's information security policy is in draft form and does not include all of the required seven elements. Questioned Costs: None. Context: The District's information security policy does not contain all seven elements required by the Gramm-Leach-Bliley Act. Cause: The District's information security policy is still in draft form. Effect: The District's information security policy is not in compliance with the Gramm-Leach- Bliley Act. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Views of responsible officials: Management concurs with the finding and plans to correct the finding.