HUDSON VALLEY COMMUNITY COLLEGE

Criteria: Per the Federal Register and the Federal Student Aid Electronic Communication, the deadline for the electronic submission of the Fiscal Operations Report for the 2024-25 and the Application to Participate for 2026-27 (“FISAP”) was 11:59 pm eastern time on October 1, 2025. Transmission must be completed prior to midnight. Additionally, the signature page must be printed, signed, and mailed by the October 1, 2025 deadline. Condition: The College did not submit the FISAP for Award Year July 1, 2024 - June 30, 2025 (Application Award Year July 1, 2026 - June 30, 2027) until April 17, 2026, with revisions submitted on May 5, 2026. Additionally, the most recent signature page is dated April 28, 2026. Cause: The College Financial Aid Department was affected by significant staff turnover whereas when it was time to prepare and submit the FISAP, the employees available were not those who had been with the College during the award year in the report which resulted in the College not meeting the submission and filing deadline. Effect: The College is not in compliance with the federal regulations regarding the submission of the FISAP and related signature page which may require the College to return campus-based aid drawn down for the FSEOG and FWS programs in the amount of approximately $517,827 (FSEOG of $267,966 and FWS of $249,861) for the 2024-2025 award year. Additionally, this may impact the College’s eligibility to receive campus-based aid for the 2026-2027 school year. The College has indicated the DOE accepted the late submission and does not expect any material adverse impact to the funding of these programs. Prevalence: The College did not submit the FISAP before the required deadline. Recommendation: The College should improve their control processes to ensure timely reporting and submission of the FISAP and related signature page. Management Response and Corrective Action Plan: The College recognizes the importance of timely and accurate reporting. The significant turnover during the fiscal year in the Financial Aid department resulted in challenges of timely reporting. The late submission of the FISAP was accepted by the DOE and the College does not expect any material adverse impact to the funding of these programs. The College is currently reviewing current staffing levels and other resources to ensure compliance with all regulations and timely submissions moving forward.

The College recognizes the importance of timely and accurate reporting. The significant turnover during the fiscal year in the Financial Aid department resulted in challenges of timely reporting. The late submission of the FISAP was accepted by the DOE and the College does not expect any material adverse impact to the funding of these programs. The College is currently reviewing current staffing levels and other resources to ensure compliance with all regulations and timely submissions moving forward.

Criteria: Per CFR 668.164, credit balances resulting from the application of Title IV aid must be paid directly to the student or parent as soon as possible, but no later than fourteen days after the credit balance occurred or fourteen days after the first day of classes if the credit balance occurred on or before the first day of class of a payment period. Condition: The College self-identified that for a significant number of credit balances resulting from Title IV aid, refunds were not processed and paid within the 14 day timeframe as required by CFR 668.164. Cause: The College noted during fiscal year 2024-25, the College’s system stopped calculating students’ refund amounts and processing the refunds automatically. The College staff began manually calculating refund amounts which created a backlog to processing the refunds timely. Additionally, there has been a high level of turnover of College employees in the department that resulted in further disruptions in the flow of the refund process. These factors contributed to the College’s ability to consistently meet the 14 day timeframe as required. Effect: The College was not in compliance with the federal regulations regarding the return of credit balances to students. Prevalence: This matter effected a significant number of students’ accounts, however the full pervasiveness of this issue could not be determined by management at this moment. Recommendation: The College should evaluate and enhance its procedures and report programming to ensure all Title IV credit balances are refunded timely. Management Response and Corrective Action Plan: The College recognizes the importance of complying with all regulations including the timely refunding of credit balances resulting from Title IV aid. As noted above, during the fiscal year 2024-25, the College’s system stopped automatically calculating students’ refund amounts which resulted in the College staff having to manually calculate the refunds. This labor-intensive manual process in addition to staff turnover during the fiscal year contributed to systematic delays in the College’s ability to consistently meet the 14-day refund disbursement requirement. To address the problem, the College established a cross-functional task force consisting of staff from Information Technology, the Bursar’s Office, and the Comptroller’s Office. The task force has engaged peer SUNY institutions to better understand current practices. Additionally, the College is in the process of filling vacant positions (including a Bursar) in addition to enhancing control processes to ensure accurate calculations and timely refunds moving forward as of May 2026.

The College recognizes the importance of complying with all regulations including the timely refunding of credit balances resulting from Title IV aid. As noted above, during the fiscal year 2024-25, the College’s system stopped automatically calculating students’ refund amounts which resulted in the College staff having to manually calculate the refunds. This labor-intensive manual process in addition to staff turnover during the fiscal year contributed to systematic delays in the College’s ability to consistently meet the 14-day refund disbursement requirement. To address the problem, the College established a cross-functional task force consisting of staff from Information Technology, the Bursar’s Office, and the Comptroller’s Office. The task force has engaged peer SUNY institutions to better understand current practices. Additionally, the College is in the process of filling vacant positions (including a Bursar) in addition to enhancing control processes to ensure accurate calculations and timely refunds moving forward as of May 2026.

CFDA Number: Various – SFA Cluster Criteria: Per 16 CFR 314.4 (c)(5), the College is required to implement multi-factor authentication for any individual accessing any information system, unless the Qualified Individual has approved in writing the use of reasonably equivalent or more secure access controls. Per the FSA Electronic Announcement GENERAL-23-09, institutions were required to implement this rule by June 9, 2023. Condition: The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline. Cause: The College is currently still in the process of implementing multi-factor authentication on the WIReD system. Effect: The College is not in compliance with the requirement set by the Safeguards Rule under the Gramm-Leach-Bliley Act. Prevalence: Implementing multi-factor authentication proved to be more complicated and timeconsuming for the student information system WIReD. Multi-factor authentication or equivalent access controls are in place for all other systems containing student information, and all other elements of the Safeguards Rule appear to be in place as required. Recommendation: The College should implement multi-factor authentication for all systems as soon as possible and reference MFA in the written Information Security Program. The College should also enhance its training and procedures to ensure that any future adjustments to Gramm Leach Bliley Act continue to be met in a timely manner. Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024.

Financial Statements Management’s Response and Planned Corrective Action: Management acknowledged that implementation of multi-factor authentication for the WIReD system has taken more time due to the complexity of the systems in place. The multi-factor authentication on the WIReD system was implemented and went into effect on March 26, 2024. Corrective Action Plan Page Finding Number: 2023-002 Federal Assistance Listing Number: Various – SFA Cluster Year Ended: August 31, 2023 Responsible Individual: William Jojo Chief Information Officer Management’s Response and Corrective Action Plan: The College agrees with the finding and recommendation. The College did not fully implement multi-factor authentication by June 9, 2023, which was the effective deadline. On identification of the issue, management responded that implementation of multi-factor authentication for certain student information systems (Banner, WIReD) has taken more time due to the complexity of the systems in place. The College also has secure access controls in place for Banner, which cannot be accessed offsite and requires email log-ins through Citrix Workspace. However, multi-factor authentication has not been implemented on WIReD, which is another system where students can access their financial aid records. The College will implement multi-factor authentication across all systems for 2024. The above plan will be implemented by March 28, 2024.

CFDA Number: 84.268 Federal Direct Loans Criteria: Per 34 CFR 668.165(a)(3), the College must notify the student or parent of an anticipated Direct Loan disbursement in writing no earlier than 30 days before, and no later than 30 days after, disbursing the loan to the student?s account. Condition: For 4 out of 40 students tested, no notification was sent to the student or parent for the Direct Loan disbursements made on August 22, 2022. Cause: The incorrect award year (AY21-22) was entered for loan disbursement notifications for any disbursements that were made on August 22, 2022. All loan disbursements made on August 22, 2022 were part of award year 2022-2023. As a result of the above human error, no notifications were sent to students for the August 22, 2022 disbursements. Effect: The College is not in compliance with the federal regulations regarding the notification of direct loan disbursements to students. Prevalence: There were no notifications sent out for direct loan disbursements on August 22, 2022. The College verified that this was the only day affected by reviewing each disbursement date related to the fiscal year 2022 and verifying inputs into the notifications were done correctly. The error was corrected the next day and notifications were appropriately sent since August 23, 2022. A list of all students who received Direct Loans on August 22, 2022 was obtained and reviewed, noting that this affected 909 students. Recommendation: The College should have improved training procedures for the accounts payable staff responsible for inputting the criteria for notifications. The College should also enhance their review procedures, such as implementing a checklist to be completed by accounts payable staff each day and reviewed by Comptroller or other secondary review control over accounts payable staff, to ensure that the correct award year and other key inputs are used when setting parameters for Direct Loan disbursement notifications.

Financial Statements Management?s Response and Planned Corrective Action: On identification of the issue, management confirmed that August 22, 2022 was the only date for which the notifications were not sent out properly. This issue resulted from a lack of sufficient staff and significant turnover around August 2022. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. Corrective Action Plan Pages Finding Number: 2022-002 Federal Assistance Listing Number: 84.268 Federal Direct Loans Year Ended: August 31, 2022 Responsible Individual: Joanne Hammond Associate Comptroller Management?s Response and Corrective Action Plan: The College agrees with the finding and recommendation. There were no notifications sent out for direct loan disbursements on August 22, 2022. The College verified that this was the only day affected by reviewing each disbursement date related to the fiscal year 2022 and verifying inputs into the notifications were done correctly. The error was corrected the next day and notifications were appropriately sent since August 23, 2022. A list of all students who received Direct Loans on August 22, 2022 was obtained and reviewed, noting that this affected 909 students. Management promptly updated procedures and training to clarify to accounts payable personnel the correct parameters for the Direct Loan notifications and are working to put in place additional review controls. No further action related to the August 22, 2022 disbursements was considered necessary as students who received these disbursements would have received subsequent disbursements in which proper notification was sent. The above procedures have already been implemented.

CFDA Number: 84.425E Education Stabilization Fund (COVID 19 ? Higher Education Emergency Relief Fund ? Student Relief) Criteria: Institutions must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the Education Stabilization Fund (ESF). Institutions must also post quarterly reports timely and accurately as it relates to expenditures under the HEERF III (a)(1) Student Aid Portion. Condition: For the February and April 2022 distributions to students (related to the Spring 2022 semester), the total amount distributed exceeded the planned amount for distribution and the allocation to the eligible students did not follow the pre-determined plan which was posted publicly to the College?s website. Cause: For the February and April 2022 distributions to students, there were data input errors in assigning the dollar amount to be distributed to each student based on their EFC category. This caused a change in the amount to be distributed per student from the original pre-determined plan. Effect: The effect of the condition was an over-award to 871 students (868 of the 2,894 students in the February 2022 distribution and 3 of the 56 students in the April 2022 distribution) in the amount of $135,436 outside of the pre-determined plan which was publicly posted to the College?s website. The amount of the February and April 2022 distributions per student were not supported by the College?s plan for distribution and did not align with the plan posted publicly to the College?s website. Questioned Costs: $135,436. This was computed as the amount of the February and April 2022 distributions that were over the planned disbursement amount due to the data input error. Prevalence: The data input error was isolated to the February and April 2022 distributions. Reports by student of the previous distributions for the Fall 2021 semester and the subsequent distributions for the Fall 2022 semester were reviewed and a comparison was performed of the actual distribution per student to the planned distribution. No other instances of similar errors were identified. Recommendation: The College should enhance their review procedures. The College should have a preventative review control in place to ensure distributions are input into the system correctly and in line with the intended plan before distributing the funds to the students. The College should also have a detective control in place to review the distribution after to verify it is distributed as intended by a person separate from the one processing the distribution.

Financial Statements Management?s Response and Planned Corrective Action: The February 2022 and April 2022 distributions were the only distributions impacted by the data input error and both related to the Spring 2022 semester. Due to the error, 871 students (868 of the 2,894 students in the February 2022 distribution and 3 of the 56 students in the April 2022 distribution) received a higher distribution than was originally planned. Of the 871 students, 129 received $70 more than originally planned and 742 received $170 more than originally planned. In no event did any one student receive less than the originally planned distribution amount, and furthermore no student who received the additional funding was ineligible under the program. However, as the $135,436 that was distributed above the planned amount was not properly supported by the College?s plan for distribution due to an error, the College agrees that these monies should not be federally funded. After the error was identified in fiscal year 2023, the College decided to fund the over-awarded amount with the College?s own funds so that the federal distribution is in line with their pre-determined plan that has been publicly posted to the College?s website. After the correction, the College has available $135,436 of HEERF student funding that was already drawn down from the federal government. The College has a plan in place to distribute these monies to students in fiscal year 2023 to remain in compliance with the program. The College will correct the quarterly reporting to reflect the above changes. The College has also put in place review controls around the HEERF distribution process. No other instances of errors have occurred subsequent to the April 2022 distribution and, after the $135,436 is distributed to students in fiscal year 2023, all awarded amounts for student relief funding will have been appropriately expended through distributions to students per the program. Corrective Action Plan Pages Finding Number: 2022-004 Federal Assistance Listing Number: 84.425E Education Stabilization Fund (COVID 19 ? Higher Education Emergency Relief Fund ? Student Relief) Year Ended: August 31, 2022 Responsible Individual: Christine Lasch Comptroller Management?s Response and Corrective Action Plan: The College agrees with the finding and recommendation. For the February and April 2022 distributions to students, there were data input errors in assigning the dollar amount to be distributed to each student based on their EFC category. This caused a change in the amount to be distributed per student from the original pre-determined plan. The February 2022 and April 2022 distributions were the only distributions impacted by the data input error and both related to the Spring 2022 semester. Due to the error, 871 students (868 of the 2,894 students in the February 2022 distribution and 3 of the 56 students in the April 2022 distribution) received a higher distribution than was originally planned. Of the 871 students, 129 received $70 more than originally planned and 742 received $170 more than originally planned. In no event did any one student receive less than the originally planned distribution amount, and furthermore no student who received the additional funding was ineligible under the program. However, as the $135,436 that was distributed above the planned amount was not properly supported by the College?s plan for distribution due to an error, the College agrees that these monies should not be federally funded. After the error was identified in fiscal year 2023, the College decided to fund the over-awarded amount with the College?s own funds so that the federal distribution is in line with their pre-determined plan that has been publicly posted to the College?s website. After the correction, the College has available $135,436 of HEERF student funding that was already drawn down from the federal government. The College has a plan in place to distribute these monies to students in fiscal year 2023 to remain in compliance with the program. The College will correct the quarterly reporting to reflect the above changes. The College has also put in place review controls around the HEERF distribution process. No other instances of errors have occurred subsequent to the April 2022 distribution and, after the $135,436 is distributed to students in fiscal year 2023, all awarded amounts for student relief funding will have been appropriately expended through distributions to students per the program. The above procedures have already been implemented.

GSA_MIGRATION

GSA_MIGRATION