2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
2023-003 Assistance Listing No. 14.239 HOME Investment Partnerships Program Criteria: 2 CFR Part 200.303 establishes internal control requirements over federal awards that provides reasonable assurance the entity is managing the federal award in compliance with Federal Statutes. Condition: The Organization contracted with a third party to determine eligibility of tenants. During the year, the third party failed to complete annual recertifications timely. Internal controls should be present to monitor the activities of the third party to ensure timely completion of recertifications. Cause: The Organization relied on a third-party provider to perform the work they were contracted to perform and did not implement internal controls to monitor the services provided to ensure they complied with Federal Statutes. Effect: Annual recertifications were not performed timely. Questioned Costs: None Recommendations: The Organization should implement internal controls to monitor the activities of third-party providers to ensure the services being provided are in compliance with Federal Statutes. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan included in report.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from change. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all enrollment changes are reported within 60 days to NSLDS. Effect: Student could have inaccurate loan status if their enrollment status is not changed timely. Repeat finding: No Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from change. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all enrollment changes are reported within 60 days to NSLDS. Effect: Student could have inaccurate loan status if their enrollment status is not changed timely. Repeat finding: No Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from change. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all enrollment changes are reported within 60 days to NSLDS. Effect: Student could have inaccurate loan status if their enrollment status is not changed timely. Repeat finding: No Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from change. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all enrollment changes are reported within 60 days to NSLDS. Effect: Student could have inaccurate loan status if their enrollment status is not changed timely. Repeat finding: No Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Department of Education requires institutions 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. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Department of Education requires institutions 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. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Department of Education requires institutions 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. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Department of Education requires institutions 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. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Questioned costs: N/A Cause: The Student Financial Aid Office does not have a process in place to ensure all disbursements are reported within 15 days to COD. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: No Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023. Context: During the testing of the outstanding Title IV student check listing CLA observed seven instances of stale checks at Connors that were aged greater than 240 days. Questioned costs: N/A Cause: Connors State College had controls in place to catch stale checks and reissue, but financial personnel was not catching reissues over 240 days. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023. Context: During the testing of the outstanding Title IV student check listing CLA observed seven instances of stale checks at Connors that were aged greater than 240 days. Questioned costs: N/A Cause: Connors State College had controls in place to catch stale checks and reissue, but financial personnel was not catching reissues over 240 days. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023. Context: During the testing of the outstanding Title IV student check listing CLA observed seven instances of stale checks at Connors that were aged greater than 240 days. Questioned costs: N/A Cause: Connors State College had controls in place to catch stale checks and reissue, but financial personnel was not catching reissues over 240 days. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023. Context: During the testing of the outstanding Title IV student check listing CLA observed seven instances of stale checks at Connors that were aged greater than 240 days. Questioned costs: N/A Cause: Connors State College had controls in place to catch stale checks and reissue, but financial personnel was not catching reissues over 240 days. Effect: Funds are not returned to the Department of Education in a timely manner Repeat finding: No Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: The college was missing all of the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The institution has been in compliance with previous iterations of GLBA regulations. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements but a Qualified Individual was designated for overseeing and implementing the WISP. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned costs: N/A Cause: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Effect: Student personal information could be vulnerable Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: The college was missing all of the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The institution has been in compliance with previous iterations of GLBA regulations. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements but a Qualified Individual was designated for overseeing and implementing the WISP. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned costs: N/A Cause: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Effect: Student personal information could be vulnerable Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: The college was missing all of the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The institution has been in compliance with previous iterations of GLBA regulations. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements but a Qualified Individual was designated for overseeing and implementing the WISP. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned costs: N/A Cause: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Effect: Student personal information could be vulnerable Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program.(16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). The Code of Federal Regulations, 2 CFR 200.303, required that entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Condition: The college was missing all of the requirements from the Gramm-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The institution has been in compliance with previous iterations of GLBA regulations. The Written Information Security Program (WISP) which was required as of June 9, 2023 had missing elements but a Qualified Individual was designated for overseeing and implementing the WISP. Some controls were in place whereas others were not. They did, however, have a WISP as of the deadline but it was missing some required information. Questioned costs: N/A Cause: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Effect: Student personal information could be vulnerable Repeat finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements.Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
2023 – 003: National Student Loan Data System Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Material Noncompliance (Modified Opinion) • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023 – 003: National Student Loan Data System Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Material Noncompliance (Modified Opinion) • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023 – 002: Return of Title IV funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45-days of the College's determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45-day requirement. Repeat finding: No Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023 – 003: National Student Loan Data System Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Material Noncompliance (Modified Opinion) • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023 – 002: Return of Title IV funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45-days of the College's determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45-day requirement. Repeat finding: No Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2023 – 003: National Student Loan Data System Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2022, to June 30, 2023 Type of Finding: • Material Noncompliance (Modified Opinion) • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we noted student enrollment status changes were not properly reported or updated during the Spring 2023 term. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: No Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, 84.268, 84.033 Federal Award Identification Number and Year: P268K236759 - 2023, P033A223433 – 2023, P007A223442 - 2023, P063P222046 - 2023, P268K232046 - 2023, P033A223442 - 2023 Award Period: July 1, 2022, to June 30, 2023 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 180.300, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Per 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: The University did not retain proper documentation for suspension and debarment verification. Context: During our testing, we noted one out of five vendors tested did not have proper documentation for suspension and debarment verification. Questioned costs: None. Cause: The University doesn't have proper controls in place to ensure suspension and debarment requirements are monitored and reviewed. Effect: Failure to assess suspension and debarment could lead to the University working with unqualified vendors. Repeat finding: No Recommendation: We recommend the University review procedures to monitor and retain documentation for suspension and debarment verification. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.