CORPORATION OF MARLBORO COLLEGE

2020 ? 001 Federal agency: United States Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: Various Award Period: July 1, 2019 through August 15, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Student Status Confirmation Reports (SSCRs) submitted to the National Student Loan Data System (NSLDS) by the National Student Clearinghouse to correct enrollment reporting errors were not accepted timely. Condition: Failure to comply with the requirement to have error response files filed and accepted within the 10-day time frame. Questioned costs: None Context: During our testing of enrollment reporting, we noted instances where error reports were not corrected within the required 10-day timeframe. Cause: Error batches returned by NSLDS to NSC (the College?s servicer) were not communicated to the school. Effect: Failure to comply with timely enrollment reporting error correction requirements, and failure to correct misreported information to NSLDS. Repeat Finding: Yes Recommendation: We recommend the college implement additional controls to ensure timely reporting, processing, and tracking of SSCR error files, error file responses, and file receipt acknowledgements for data submitted to NSLDS by the Clearinghouse. Views of responsible officials: There is no disagreement with the audit finding. See Corrective Action Plan for additional details.

2020-001 Student Financial Aid Cluster ? CFDA No. Various Recommendation: Marlboro College is no longer participating in the Federal Student Aid programs and therefore a recommendation is not necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marlboro College completed its reporting as required for close out by the Department of Education. The College therefore is of the belief that an appropriate response has been taken. Name(s) of the contact person(s) responsible for corrective action: Keith Lowey, Chief Transition Officer. Planned completion date for corrective action plan: No corrective action will be taken.

2019-001

2020 ? 002 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.268 ?Federal Direct Student Loans Award Period: July 1, 2019 through August 15, 2020 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted 8 out of 14 students whose withdrawal from the College was not reported timely to the NSLDS. Questioned costs: None Context: During our audit procedures, it was noted that the College did not report students? status change timely to the NSLDS. Cause: The students? withdrawals were not reported to the NSLDS within the required timeframe. Effect: As NSLDS reporting dates impact student repayment and interest charges, it is important that student status changes are reported timely and properly to NSLDS. Repeat Finding: Yes Recommendation: We recommend that the College review its policies and procedures surrounding its reporting of enrollment status changes to NSLDS and implement a review process to ensure that errors are properly followed up on. Views of responsible officials: There is no disagreement with the audit finding. See Correction Action Plan for additional details.

2020-002 Student Financial Aid Cluster ? CFDA No. 84.268 Federal Direct Student Loans Recommendation: We recommend the College should review the policies and procedures surrounding reporting of enrollment status changes to NSLDS and implement a review process to ensure that errors are properly followed up on. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Marlboro College completed its reporting as required for close out by the Department of Education. The College therefore is of the belief that an appropriate response has been taken. Name(s) of the contact person(s) responsible for corrective action: Keith Lowey, Chief Transition Officer. Planned completion date for corrective action plan: No corrective action will be taken.

2019-004

2019 ? 001 Federal agency: United States Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: Various Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Student Status Confirmation Reports (SSCRs) submitted to the National Student Loan Data System (NSLDS) by the National Student Clearinghouse to correct enrollment reporting errors were not accepted timely. Condition: Failure to comply with the requirement to have error response files filed and accepted within the 10-day time frame. Questioned costs: None Context: During our testing of enrollment reporting, we noted instances where error reports were not corrected within the required 10-day timeframe. Cause: Error batches returned by NSLDS to NSC (the College?s servicer) were not communicated to the school. Effect: Failure to comply with timely enrollment reporting error correction requirements, and failure to correct misreported information to NSLDS. Repeat Finding: No Recommendation: We recommend the college implement additional controls to ensure timely reporting, processing, and tracking of SSCR error files, error file responses, and file receipt acknowledgements for data submitted to NSLDS by the Clearinghouse. Views of responsible officials: There is no disagreement with the audit finding.

2019-001 Student Financial Aid Cluster ? CFDA No. Various Recommendation: We recommend the college implement additional controls to ensure timely reporting, processing, and tracking of SSCR error files, error file responses, and file receipt acknowledgements for data submitted to NSLDS by the Clearinghouse. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To resolve the issues only Cathy Fuller is responding to error reports and, Cathy is tracking the error reports (and the number of days) very closely to resolve any lingering issues. Name(s) of the contact person(s) responsible for corrective action: Cathy Fuller, Registrar Planned completion date for corrective action plan: The corrective action plan was implemented during fall 2019, as soon as the auditors brought the issues to Cathy?s attention. If the United States Department of Education has questions regarding this plan, please call Cathy Fuller at 802 258 9237.

2019 ? 002 Federal agency: United States Department of Education Federal program title: Student Financial Aid Cluster CFDA Number: Various Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for eligibility requirements, we noted 1 out of 24 students tested did not have the required verification support retained in the student files. Questioned costs: $15,000 Context: During our testing of the Direct Loan and Pell Grant programs, we selected a sample of students to test for eligibility requirements, we noted 1 out of 24 students tested did not have the required verification support retained in the student files. Cause: The College's processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The College did not either obtain or retain information to support the verification process. Documentation needs to be retained to show that the verification process was completed. Repeat Finding: No Recommendation: We recommend the college should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of responsible officials: There is no disagreement with the audit finding.

2019-002 Student Financial Aid Cluster ? CFDA No. Various Recommendation: We recommend the college should review the procedures surrounding the verification process to ensue all necessary support and documentation is obtained and retained in the student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To resolve issue Kristin Hmieleski, Director of Financial Aid, created logics in the PowerFAIDS system to post the correct documents required for each student to complete when selected for the different types of verification. Additionally, the Director of Financial Aid will do a second review of each student selected for verification. Name(s) of the contact person(s) responsible for corrective action: Kristin Hmieleski, Director of Financial Aid Planned completion date for corrective action plan: Corrective action plan was implemented during spring 2019, when new Director of Financial aid set-up PowerFAIDS for the next processing cycle (2019-2020). If the United States Department of Education has questions regarding this plan, please call Kristin Hmieleski at 802 258 9237.

2019 ? 003 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.063, 84.007, 84.033 Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Condition: Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the College did not designate an individual to coordinate the information security program; did not perform a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) which are (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures and maintain documented safeguards for identified risks. Cause: The organization uses a third-party IT service provider for IT related tasks and relied on that service provider to ensure all compliance requirements are met. However, the organization should have an individual designated internally to assure compliance with the requirements of the Gramm-Leach-Bliley Act. The organization did not perform an IT risk assessment tailored specifically to the organization, identify risks or address risks identified as required by the Gramm-Leach-Bliley Act. Effect: The student personal information could be vulnerable. Repeat Finding: No Recommendation: We recommend that the College designate an individual to oversee the information security function, engage a third-party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding.

2019-002 Student Financial Aid Cluster ? CFDA No. Various Recommendation: We recommend the college should review the procedures surrounding the verification process to ensue all necessary support and documentation is obtained and retained in the student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To resolve issue Kristin Hmieleski, Director of Financial Aid, created logics in the PowerFAIDS system to post the correct documents required for each student to complete when selected for the different types of verification. Additionally, the Director of Financial Aid will do a second review of each student selected for verification. Name(s) of the contact person(s) responsible for corrective action: Kristin Hmieleski, Director of Financial Aid Planned completion date for corrective action plan: Corrective action plan was implemented during spring 2019, when new Director of Financial aid set-up PowerFAIDS for the next processing cycle (2019-2020). If the United States Department of Education has questions regarding this plan, please call Kristin Hmieleski at 802 258 9237.

2019 ? 004 Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.268 ?Federal Direct Student Loans Award Period: July 1, 2018 through June 30, 2019 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition: During our testing, we noted 3 out of 12 students whose withdrawal from the College was not reported timely to the NSLDS. Questioned costs: None Context: During our audit procedures, it was noted that the College did not report students? status change timely to the NSLDS. Cause: The students? withdrawals were not reported to the NSLDS within the required timeframe. Effect: As NSLDS reporting dates impact student repayment and interest charges, it is important that student status changes are reported timely and properly to NSLDS. Repeat Finding: No Recommendation: We recommend that the College review its policies and procedures surrounding its reporting of enrollment status changes to NSLDS and implement a review process to ensure that errors are properly followed up on. Views of responsible officials: There is no disagreement with the audit finding.

2019-004 Student Financial Aid Cluster ? CFDA Number 84.268 ? Federal Direct Student Loans Recommendation: We recommend the college review its policies and procedures surrounding its reporting of enrollment status changes to NSLDS and implement a review process to ensure that errors are properly followed up on. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We began reviewed our Clearinghouse Transmission schedule and began monthly reporting rather there was new information or not. Name(s) of the contact person(s) responsible for corrective action: Cathy Fuller, Registrar Planned completion date for corrective action plan: Corrective action plan was implemented on October 11, 2019 (by adding the first of many additional transmissions). If the United States Department of Education has questions regarding this plan, please call Cathy Fuller at 802 251 7609.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

2015-001