EIN: 381711021
UEI: Y5BRDNPUAFB5
Audited by: REHMANN ROBSON LLC
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 4, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 4, 2026 (34 days ago).
What is a management decision? →2025-002 - Noncompliance with Enrollment Status Change Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268; Award Numbers P007A231980, P007A241980, P033A241980, P063P231624, P063P241624. Criteria. Per 34 C.F.R. §685.309 and NSLDS Enrollment Reporting requirements, institutions must report accurate and complete student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of becoming aware that a student’s enrollment status has changed. Condition. During our testing of enrollment status change reporting, we noted one instance in which a student’s status change was not reported to NSLDS within 60 days. Cause. The delay occurred because the student was assigned a different coding structure within the College’s system due to their foreign student status. This coding difference resulted in the student being excluded from the standard status-change reporting process, causing the change to be overlooked when NSLDS reporting was performed. Effect. As a result of this condition, the College was out of compliance with enrollment reporting requirements. Questioned Costs. No costs are requried to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students, including those with unique or foreign-student coding, are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. View of Responsible Officials. Management agrees with the finding and has updated internal reports and review procedures to ensure all student types are included in enrollment reporting workflows. Management has prepared a corrective action plan.
Show full finding ▾Hide full finding ▴2025-002 - Noncompliance with Enrollment Status Change Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Special Tests & Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268; Award Numbers P007A231980, P007A241980, P033A241980, P063P231624, P063P241624. Criteria. Per 34 C.F.R. §685.309 and NSLDS Enrollment Reporting requirements, institutions must report accurate and complete student enrollment status changes to the National Student Loan Data System (NSLDS) within 60 days of becoming aware that a student’s enrollment status has changed. Condition. During our testing of enrollment status change reporting, we noted one instance in which a student’s status change was not reported to NSLDS within 60 days. Cause. The delay occurred because the student was assigned a different coding structure within the College’s system due to their foreign student status. This coding difference resulted in the student being excluded from the standard status-change reporting process, causing the change to be overlooked when NSLDS reporting was performed. Effect. As a result of this condition, the College was out of compliance with enrollment reporting requirements. Questioned Costs. No costs are requried to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted. Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students, including those with unique or foreign-student coding, are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. View of Responsible Officials. Management agrees with the finding and has updated internal reports and review procedures to ensure all student types are included in enrollment reporting workflows. Management has prepared a corrective action plan.
Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026
FAC accepted this audit on March 12, 2025 — management decision was due September 12, 2025.
Cost of Attendance Input Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A231980, P033A231980, P063P221624, P063P231624, P268K231624, and P268K241624. Criteria. The total aid awarded is not to exceed the student's financial need or cost, as specified by the 34 CFR 668.42 (FWS), 34 CFR 673.5 and 673.6 (FSEOG); and 34 CFR 685.301 (Direct Loan) per the Compliance Supplement. Condition. There was an input error in the summer transportation component of the cost of attendance calculation. Instead of the on-campus students being designated with their own rate ($405), it was instead set to "All students 2023-2024." Cause. The College does not have a review process in place for ensuring the inputs used in the cost of attendance determination are accurate. Effect. As a result of this condition, eight students received more aid than they were eligible to receive, resulting in loan adjustments of $2,858. It is our understanding that on September 23, 2024, the College updated and sent the changes to the Common Origination and Disbursement (COD) system. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College implement a review process to ensure the inputs used in the cost of attendance determination are accurate and that the COA calculation is being reviewed by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Cost of Attendance Input Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Eligibility). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A231980, P033A231980, P063P221624, P063P231624, P268K231624, and P268K241624. Criteria. The total aid awarded is not to exceed the student's financial need or cost, as specified by the 34 CFR 668.42 (FWS), 34 CFR 673.5 and 673.6 (FSEOG); and 34 CFR 685.301 (Direct Loan) per the Compliance Supplement. Condition. There was an input error in the summer transportation component of the cost of attendance calculation. Instead of the on-campus students being designated with their own rate ($405), it was instead set to "All students 2023-2024." Cause. The College does not have a review process in place for ensuring the inputs used in the cost of attendance determination are accurate. Effect. As a result of this condition, eight students received more aid than they were eligible to receive, resulting in loan adjustments of $2,858. It is our understanding that on September 23, 2024, the College updated and sent the changes to the Common Origination and Disbursement (COD) system. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College implement a review process to ensure the inputs used in the cost of attendance determination are accurate and that the COA calculation is being reviewed by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Cost of Attendance Input Error. Auditor Description of Condition and Effect. There was an input error in the summer transportation component of the cost of attendance calculation. Instead of the on-campus students being designated with their own rate ($405), it was instead set to "All students 2023-2024." As a result of this condition, eight students received more aid than they were eligible to receive, resulting in loan adjustments of $2,858. It is our understanding that on September 23, 2024, the College updated and sent the changes to the Common Origination and Disbursement (COD) system. Auditor Recommendation. We recommend that the College implement a review process to ensure the inputs used in the cost of attendance determination are accurate and that the COA calculation is being reviewed by an independent second individual. Corrective Action. Upon discovery of the cost of attendance input error, the College went back through all summer non-on-campus students to determine if their aid was greater than it should have been and made updates to the COD system, as necessary. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. September 23, 2024.
Michigan Reconnect Expansion Calculation Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. As outlined in State of Michigan's Michigan Reconnect Expansion program guide, the Reconnect scholarship program is a last-dollar scholarship, which is equal to the difference between in-district tuition and fees (i.e., tuition, contact hours and mandatory fees) and any Pell Grant and any state tuition-restricted scholarships or awards that a student receives following the packaging order. Condition. The amount of scholarship a student is eligible to receive from the Michigan Reconnect Expansion grant is dependent on the total cost of tuition and fees as well as other financial aid received (Pell and Tuition Restricted Scholarships). When performing the calculation, the College mistakenly included tuition related to welding programs in with the fees. Cause. The College performs a review by selecting a group of students who are manually reviewed before they disburse funds for the semester. The overpayment of Michigan Reconnect Expansion scholarship funds was missed during the review of the calculation, as the two students with errors were not a part of the manual review. Effect. As a result of this condition, two students' scholarship calculations were incorrect, resulting in an overpayment of $3,054 to those students. It is our understanding that on October 30, 2024, the College refunded this amount to the Michigan Department of Treasury for those affected by this calculation error. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs over the $25,000 threshold. Recommendation. We recommend that the College follow the review processes they have in place and include formal documentation showing the preparer is a separate individual from the reviewer. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Michigan Reconnect Expansion Calculation Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. As outlined in State of Michigan's Michigan Reconnect Expansion program guide, the Reconnect scholarship program is a last-dollar scholarship, which is equal to the difference between in-district tuition and fees (i.e., tuition, contact hours and mandatory fees) and any Pell Grant and any state tuition-restricted scholarships or awards that a student receives following the packaging order. Condition. The amount of scholarship a student is eligible to receive from the Michigan Reconnect Expansion grant is dependent on the total cost of tuition and fees as well as other financial aid received (Pell and Tuition Restricted Scholarships). When performing the calculation, the College mistakenly included tuition related to welding programs in with the fees. Cause. The College performs a review by selecting a group of students who are manually reviewed before they disburse funds for the semester. The overpayment of Michigan Reconnect Expansion scholarship funds was missed during the review of the calculation, as the two students with errors were not a part of the manual review. Effect. As a result of this condition, two students' scholarship calculations were incorrect, resulting in an overpayment of $3,054 to those students. It is our understanding that on October 30, 2024, the College refunded this amount to the Michigan Department of Treasury for those affected by this calculation error. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs over the $25,000 threshold. Recommendation. We recommend that the College follow the review processes they have in place and include formal documentation showing the preparer is a separate individual from the reviewer. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Michigan Reconnect Expansion Calculation Error. Auditor Description of Condition and Effect. The College’s review process for the Michigan Reconnect Grant scholarships is performed by manually reviewing a select group of students before funds are disbursed. Two students who were not a part of this selected group had tuition costs mistakenly included with their fees. As a result of this condition, two students’ scholarship calculations were incorrect, resulting in an overpayment of $3,054 to those students. It is our understanding that on October 30, 2024, the College completed the F4F Reconnect refund worksheet and mailed a check with the amount to be returned to the U.S. Department of Treasury. Auditor Recommendation. We recommend that the College follow the review processes they have in place and include formal documentation showing the preparer is a separate individual from the reviewer. Corrective Action. Upon discovery of the Michigan Reconnect Expansion calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has modified their review process to now require two signoffs, one to document the preparer and one to document the reviewer. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. October 30, 2024.
Michigan Reconnect Expansion Refund Calculation Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. As outlined in State of Michigan's Michigan Reconnect Expansion program guide, the Reconnect scholarship program is a last-dollar scholarship, which is equal to the difference between in-district tuition and fees (i.e., tuition, contact hours and mandatory fees) and any Pell Grant and any state tuition-restricted scholarships or awards that a student receives following the packaging order. Condition. The student development fees and the technology fees that were required to be included in the scholarship refund calculation were missed for one student. Cause. The College does not have a formal review process where a second individual looks over the refund calculation to ensure errors are caught before the returns are processed. Effect. As a result of this condition, one refund calculation for the grant was incorrect, resulting in an underpayment of $752. It is our understanding that on December 16, 2024, the College refunded this amount to the Michigan Department of Treasury for those affected by this calculation error. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs over the $25,000 threshold. Recommendation. Management has already taken appropriate corrective action by updating the returns for the student impacted by the refund calculation error. However, we recommend that the College implement a review process to ensure that any correction is being reviewed by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Michigan Reconnect Expansion Refund Calculation Error. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. As outlined in State of Michigan's Michigan Reconnect Expansion program guide, the Reconnect scholarship program is a last-dollar scholarship, which is equal to the difference between in-district tuition and fees (i.e., tuition, contact hours and mandatory fees) and any Pell Grant and any state tuition-restricted scholarships or awards that a student receives following the packaging order. Condition. The student development fees and the technology fees that were required to be included in the scholarship refund calculation were missed for one student. Cause. The College does not have a formal review process where a second individual looks over the refund calculation to ensure errors are caught before the returns are processed. Effect. As a result of this condition, one refund calculation for the grant was incorrect, resulting in an underpayment of $752. It is our understanding that on December 16, 2024, the College refunded this amount to the Michigan Department of Treasury for those affected by this calculation error. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs over the $25,000 threshold. Recommendation. Management has already taken appropriate corrective action by updating the returns for the student impacted by the refund calculation error. However, we recommend that the College implement a review process to ensure that any correction is being reviewed by an independent second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Michigan Reconnect Expansion Refund Calculation Error. Auditor Description of Condition and Effect. The student development fees and the technology fees that were required to be included in the scholarship refund calculation were missed for one student. As a result of this condition, one refund calculation for the grant was incorrect, resulting in an underpayment of $752. It is our understanding that on December 16, 2024, the College refunded this amount to the U.S. Department of Treasury for those affected by this calculation error. Auditor Recommendation. Management has already taken appropriate corrective action by updating the returns for the student impacted by the refund calculation error. However, we recommend that the College implement a review process to ensure that any correction is being reviewed by an independent second individual. Corrective Action. The College has performed the necessary steps to correct the error and will amend the refund calculation process to ensure that a second individual is reviewing the work performed. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. December 16, 2024.
Untimely Report Submission. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. The Academic Catch-Up program Memorandum of Understanding between Michigan Community College Association (MCCA) and Bay de Noc Community College outlines the submission of required reporting to MCCA on a quarterly basis by certain dates. Condition. The Academic Catch-Up program quarterly reports were not submitted timely by required deadlines. Cause. The College does not have a process to track when reports are due. Effect. As a result of this condition, two of the four quarterly reports submitted in fiscal year 2024 were after the required deadline. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College develop procedures to track when reports are due and have an independent second individual perform a review to ensure accurate and timely submissions. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Untimely Report Submission. Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; Assistance Listing Number 21.027; Award Number SLFRP0127. Criteria. The Academic Catch-Up program Memorandum of Understanding between Michigan Community College Association (MCCA) and Bay de Noc Community College outlines the submission of required reporting to MCCA on a quarterly basis by certain dates. Condition. The Academic Catch-Up program quarterly reports were not submitted timely by required deadlines. Cause. The College does not have a process to track when reports are due. Effect. As a result of this condition, two of the four quarterly reports submitted in fiscal year 2024 were after the required deadline. Questioned Costs. No costs were required to be questioned as a result of this finding insomuch as our testing did not reveal any unallowed costs. Recommendation. We recommend that the College develop procedures to track when reports are due and have an independent second individual perform a review to ensure accurate and timely submissions. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Untimely Report Submission. Auditor Description of Condition and Effect. The Academic Catch-Up program quarterly reports were not submitted timely. As a result of this condition, two of the four quarterly reports submitted in fiscal year 2024 were after the required deadline. Auditor Recommendation. We recommend that the College develop procedures to track when reports are due and have an independent second individual perform a review to ensure accurate and timely submissions. Corrective Action. The Senior Accountant will review the reporting procedures to ensure accurate and timely report submissions. The Senior Accountant will check the timestamps of each report to ensure timely reporting. Responsible Person. Sherri Viau, Senior Accountant. Anticipated Completion Date. June 30, 2025.
FAC accepted this audit on March 8, 2024 — management decision was due September 8, 2024.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The total number of calendar days in an enrollment period includes all days within the period, excluding scheduled breaks of at least five consecutive days, as specified by the 34 CFR 668.22(f) Compliance Supplement. Condition. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. Cause. The College does not have a review process in place for reporting the number of days used in the enrollment period. Effect. As a result of this condition, Return of Title IV ("R2T4") calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 in excess funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is being reviewed by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. A break of at least five consecutive days was not excluded from the reported enrollment period for the Fall 2022 semester, which resulted in the calculation being incorrect for all students who had returns in the Fall 2022 semester. As a result of this condition, Return of Title IV calculations were incorrect for 60 students for the Fall 2022 semester, resulting in $10,459 less funds returned to the U.S. Department of Education. It is our understanding that on July 24, 2023, the College repaid the 60 students affected by this calculation error. Auditor Recommendation. We recommend that the College implement a review process to ensure the number of enrollment days used in the Return of Title IV calculations is accurate and that the R2T4 calculation is reviewed by a second individual. Corrective Action. Upon discovery of the Return of Title IV Calculation error, the College went through and made corrections to all student accounts affected. To prevent a similar problem arising in the future, the College has developed a review process that will require an additional sign‐off for the total days to be used in the calculation. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. July 24, 2023.
Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Special Tests and Provisions). Program. Student Financial Assistance Cluster; U.S. Department of Education; Assistance Listing Numbers 84.007, 84.033, 84.063, and 84.268; Award Numbers P007A221980, P007A211980, P033A221980, P063P221624, P063P211624, P268K231624, and P268K221624. Criteria. The Federal Trade Commission (FTC) states that the Gramm Leach Bliley Act "requires financial institutions to explain their information‐sharing practices to their customers and safeguard sensitive data." Condition. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. Cause. The College does not have a review process in place for ensuring all safeguard policies set forth in the Gramm Leach Bliley Act are included in its written security policy. Effect. As a result of this condition, the College isn't meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Questioned Costs. No costs are required to be questioned as a result of this finding, insomuch as no unallowable expenditures were noted. Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. View of Responsible Officials. Management agrees with this finding and has prepared a Corrective Action Plan.
Auditor Description of Condition and Effect. The most recent Gramm Leach Bliley Policy fails to address the implementation of safeguards to control the risks the institution identifies through its risk assessment, the testing or monitoring the effectiveness of the safeguards implemented, and the evaluation and adjustment of its information security program in light of the results of the required testing and monitoring. As a result of this condition, the College is not meeting the safeguard requirements necessary to comply with the FTC. In addition, the lack of safeguard controls creates an increased risk to highly sensitive data that is possessed by the College. Auditor Recommendation. We recommend that the College implement procedures to ensure that all Gramm Leach Bliley Policies are met and verified by a second individual. Corrective Action. Currently, the College is reviewing the compliance requirements for the Gramm Leach Bliley Act and will amend the current policy to ensure that each safeguard is being addressed within the policy. Responsible Person. Jonathan Lane, Director of IT. Anticipated Completion Date. June 30, 2024
FAC accepted this audit on February 16, 2023 — management decision was due August 16, 2023.
FAC accepted this audit on December 12, 2021 — management decision was due June 12, 2022.
FAC accepted this audit on April 4, 2021 — management decision was due October 4, 2021.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on November 5, 2018 — management decision was due May 5, 2019.
FAC accepted this audit on November 1, 2017 — management decision was due May 1, 2018.
FAC accepted this audit on November 27, 2016 — management decision was due May 27, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in Michigan →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Add it to a monitored group and get alerted when a new audit, finding, repeat finding, or management-decision deadline shows up — instead of checking back.
Checking several at once? Portfolio view →
© 2026 Single Audit Intelligence. All data is public domain.
