FINGER LAKES COMMUNITY COLLEGEHigher Education

Finding 2025-001 - 10.855 - Distance Learning and Telemedicine Loans and Grants Federal Agency – U.S. Department of Agriculture Grant Period – Year ended August 31, 2025 Compliance Requirement – L. Reporting Criteria – A requirement of receiving the Distance Learning and Telemedicine Loans and Grants was to complete project performance and financial reporting on the grant. Condition – The financial reporting of the completed SF 425 Federal Financial Report was submitted, and funds were received, which triggered the annual project performance report filing to be completed by January 31, 2026. The required annual project performance activity report was not filed by the due date. Context – The College has an obligation to ensure that all grants administered and expended within the fiscal year are appropriately monitored and all compliance requirements are satisfied. Cause – The former Director of Grants Development, who was the lead on the grant, left the College in September 2025 and had not communicated that the reporting was required to be completed. There was no formal process for tracking or communicating the status of grant requirements by anyone other than the Director, this resulted in the College missing this requirement. Effect – The annual project performance activity report was not filed timely. Recommendation – We recommend the College establish a formal, documented shared communication between the department responsible for administering the grant and the College finance department which outlines the critical grant requirements including, but not limited to, initial, interim and final reporting. This will help to ensure compliance with the necessary grant requirements in the event of turnover or absence.

Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 Criteria: Institutions participating in Title IV programs are required to comply with various laws and regulations as part of their signed Program Participation Agreement (PPA), including but not limited to, the Federal Trade Commission’s Gramm-Leach-Bliley Act (GLBA) Safeguards Rule (Title 16, Chapter I, Subchapter C, Part 314). Condition: The College has not performed a thorough information security risk assessment which should include consideration of internal and external risks and the sufficiency of the safeguards in place to control the risks identified. Many of the policies in place are outdated and have not been updated for potential changes in the College’s operations. Given the pace of change in the technology environment, outdated policies are unlikely to fully capture current circumstances. Cause: The College’s information security program does not include procedures for the performance of regular risk assessments. Effect: As the College has not performed a thorough information security risk assessment, it may be unaware of the risks to its sensitive data, specifically datasets protected under GLBA. Many policies are outdated and may not reflect the actual processes in place. Recommendation: The College should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. As part of this process, the College should then review the current policies and procedures at least annually to determine if any updates should be made.

Finding 2022-002 ? 84.268, 84.063, 84.033, 84.007 Student Financial Assistance Cluster Federal Agency ? U.S. Department of Education Grant Period ? Year ended August 31, 2022 Criteria ? In accordance with Title IV of the Higher Education Act of 1965 (Title IV) the College is required to document and determine the date of a student?s withdrawal and calculate the return of their earned student financial assistance. Condition ? There was no individual knowledgeable of the R2T4 process to lead and ensure calculations were performed timely and accurately. Context ? A sample of 40 withdrawal calculations was selected from a population of 560 students throughout the fiscal year. Our sample was a statistically valid sample. Cause ? In fiscal 2021, the College?s Director of Student Financial Aid resigned, and the responsibilities of the withdrawals were transitioned from the Office of Student Accounts to Financial Aid. During the transition, the Student Accounts staff who was knowledgeable of the withdrawal process retired, leaving the remaining staff in both offices unfamiliar with the process. A new director was hired in May 2021 and tasked with restructuring the Department, training staff, and developing policies and procedures over processes, including R2T4?s. Effect ? Many improvements to the R2T4 process were noted in fiscal 2022, however, there were approximately 20 calculations in our sample that had to be redone based on a review by the Director. As a result, 22 of our sample of 40 student R2T4?s was recalculated due to incorrect withdrawal dates or incorrect aid disbursed entered into the initial calculation. All R2T4?s for fiscal 2022 were reviewed and updated. Recommendation ? We recommend the College review its current training programs and ensure individuals understand their responsibilities and how to perform assigned tasks. The College should continue training individuals as an opportunity for strengthening the process and ensuring cross-training on the R2T4 calculations. This process should include formal communication with all departments involved to ensure everyone is aware of their responsibilities. View of Responsible Officials ? We accept the findings of the Financial Aid Single Audit and we will be implementing new policies and training procedures going forward. See Corrective Action Plan.

Finding 2022-003 ? 84.425 COVID-19 Education Stabilization Fund Federal Agency ? U.S. Department of Education Grant Period ? Year ended August 31, 2022 Criteria ? A requirement of receiving and accepting the Higher Education Emergency Relief Fund (HEERF) grant is that quarterly reporting of both the student and institutional portions be made publicly available on the College?s website. There are specific required disclosures for each round of student HEERF grants that must be disclosed, along with the Department of Education?s prescribed institutional quarterly reports. All HEERF institutional quarterly reports and student grant data must remain on the College?s website for a period of three years subsequent to the final annual reporting. Condition ? As part of the audit, we were unable to easily search or locate the required reporting on the College?s website. Effect ? The reports posted and available on the College?s website are not complete, up to date, or easily accessible. The College is not in compliance with the required reporting. Cause ? Over the past couple of years, the college has experienced significant turnover in administrative positions resulting in a lack of knowledge exchange or understanding of the reporting requirements of HEERF. Recommendation ? We recommend the College familiarize themselves with the required elements and update their website disclosures as soon as possible with all information. Certain reports have specific prescribed naming conventions for the reports to be posted. The College should ensure all documents and data are posted and easily accessible on the College?s website. View of Responsible Officials ? We acknowledge that our HEERF webpages do not include the required sections for the three HEERF awards and will be updating them to include all required elements.

Finding 2021-003 ? 84.268, 84.063, 84.033, 84.007 Student Financial Assistance Cluster Federal Agency ? U.S. Department of Education Grant Period ? Year ended August 31, 2021 Criteria ? In accordance with Title IV of the Higher Education Act of 1965 (Title IV) the College is required to document and determine the date of a student?s withdrawal and calculate the return of their earned student financial assistance. Condition ? There was no individual knowledgeable of the R2T4 process to lead and ensure calculations were performed timely and accurately. Context ? A sample of 40 withdrawal calculations was selected from a population of 419 students throughout the fiscal year. Our sample was a statistically valid sample. Cause ? In fiscal 2021, the College?s Director of Student Financial Aid resigned, and the responsibilities of the withdrawals were transitioned from the Office of Student Accounts to Financial Aid. During the transition, the Student Accounts staff who was knowledgeable of the withdrawal process retired, leaving the remaining staff in both offices unfamiliar with the process. Effect ? As a result of the vacancy, the process was not maintained, and the following were noted: ? 14 students had no documentation of their date of withdrawal, which was used in the R2T4 calculation, ? 5 students had the date of withdrawal which the calculation had been based on, not match the provided supporting documentation from the registrar, ? 12 students were not reported to the Clearinghouse within 45 days of the College?s date of determination of the student?s withdrawal, ? 6 students had different dates used on the R2T4 from what was documented in their file, ? 1 student?s R2T4 was calculated based on the incorrect number of calendar days in the semester, ? There was no formal documented review of the completed R2T4 calculations to ensure accuracy. Recommendation ? We recommend the College review their current policies and procedures to ensure documentation is in place in the event of another turnover or extended vacancy. With the new Director in place, this provides the College opportunity for strengthening the process and ensuring cross-training on the R2T4 calculations. This process should include formal communication with all departments involved in the process to ensure everyone is aware of their responsibilities. Part of the process should also assign the responsibility of review for the calculations to ensure all required elements are complete and supporting documentation is maintained. View of Responsible Officials ? The College accepts the observations and recommendations and is working within its system to establish processes and procedures for return to Title IV funds based on student withdrawals from the College. The director of financial aid, Megan Kennerknecht has been tasked with correcting the issues found in the major federal award program audit.

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