WESTERN TECHNICAL COLLEGE DISTRICT

Criteria – An institution’s written information security program must address the required minimum seven elements. Condition – During our audit, the College was asked to provide its written information security program related to Gramm-Leach-Bliley required policies. The College confirmed it did not have appropriately updated written policies during the audit period, which is required under the federal student aid program. Cause - There was an oversight by the College. Possible Asserted Effect - The College does not have a written information security program that is in compliance with Gramm-Leach-Bliley. Known Questioned Costs - None Recommendation - The institution should update its written information security plan to include all seven required elements of the Gramm-Leach-Bliley Act. Views of Responsible Officials - Management agrees with the finding. Upon notification by Wipfli, Western has updated written policies/procedures to ensure that the written security program addresses all seven requirements.

Issue identified: An Institution's written information security program must address the required minimum seven requirements of the Gramm-Leach Bliley Act. Program Affected: Student Financial Assistance Cluster Corrective Action: - Upon notification of the finding by Wipfli, Western is updating written policy/procedures to ensure that our written security program addresses all seven requirements of the Gramm-Leach Bliley policies. -We are running our penetration tests each quarter to ensure that we are maintaining security as needed in education at Western. -The internal testing and quarterly tests results we will be running will be performed during the last month of each quarter for review upon request. Person Responsible: Primary - Joan Pierce, CIO, Secondary - Michael Caretta, IT Director

Criteria – Per 34 CFR 685.309, schools must complete and return within 30 days the NSLDS Reporting roster file sent by the Department of Education. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. Condition – Our testing disclosed 3 students, out of the 25 students tested, who were not reported to NSLDS or were not reported timely to NSLDS. Cause - There was an oversight by the College. Possible Asserted Effect - The College did not report information accurately or timely to NSLDS. Known Questioned Costs - None Recommendation - The institution should ensure they are reporting all students who received Title IV funding accurately and timely to NSLDS. Views of Responsible Officials – Management agrees with the finding. Upon notification of the situation by Wipfli, Western has identified several new processes to ensure our students are being reported to the NSLDS within the required time frame.

Upon Notification of the situation by Wipfli, Western had identified several new processes to assure our students are being reported to NSLDS within the 60-day period. 1. Resolved: Western worked with Ellucian Services to review and update our savedlist for National Student Clearinghouse reporting. We discovered the savedlist excluded a subset of student, which prevented their enrollment from being updated correctly. The savedlist is now updated. 2. Update our Admissions Policy (E0200) and Procedure (E0200p9(1)) to direct students on how to officially withdraw from the College. This will help us identify students who do not plan to return to the College. We will create a report of students who officially withdraw from the College and update their status on National Student Clearinghouse website in a timely manner. 3. Identify a process to update the enrollment status for students who receive an extenuating drop for courses. We will develop a report to monitor and update on the National Student Clearinghouse website. 4. Identify a process to update the enrollment status for students who unofficially withdraw from a session 1 course which impacts their enrollment status. We will develop a report to monitor and update the National Student Clearinghouse website. Person Responsible: Lyndsey Thomas, Registrar Projected Completion Date: June 1, 2026

2019-001 Late Enrollment Reporting for Loan Programs Program Affected - Student Financial Assistance Cluster (Title IV Programs) Criteria - Per 34 CFR 685.309, schools must complete and return within 30 days the Enrollment Reporting roster file sent by the Department of Education. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third party servicer. Unless the school expects to complete its next roster within 60 days, the school must notify the lender or the guaranty agency within 30 days, if it discovers that a student who received a loan either did not enroll or ceased to be enrolled on at least a half-time basis. Condition - During our testing of enrollment reporting for 2019, we selected a total of 71 students who had either graduated or ceased enrollment during the year. For five out of the 71 students, we noted that their status was not properly updated within the required timeframe. Known Questioned Costs - $0 Cause - For students who received late approval to graduate, Western's procedures did not appropriately identify and update their status. Several other students were identified by Western, but were not properly identified by their third-party servicer. Effect - The Clearinghouse and lenders were not notified within the proper time period that students had graduated and ceased enrollment. Recommendation - We recommend the personnel at Western review and update their procedures for reporting graduate students to the Clearinghouse to ensure that students who graduate under uncommon circumstances are properly updated within the required timeframes. Western should also monitor the activities of their third-party servicer to ensure that the udpates they submit are properly reflected in the student's enrollment history. Views of Responsible Official - Upon notification of the situation by Wipfli, Western updated the records of the identified students to ensure that their status has been appropriately updated to NSLDS. Additionally, Western has identified several new processes to assure our graduates are being reporting to the NSLDS within the required time frame.

Western Technical College submits the following corrective action plan for the identified finding for the year ended June 30, 2019. Finding 2019-001- Late Enrollment Reporting for Loan Programs Corrective Action Upon notification of the situation by Wipfli, Western has identified several new processes to assure our graduates are being reporting to the NSLDS within the 60-day period. 1. Create new reports to identify courses not applying to the students' academic plans. Manually update these courses once identified. 2. Send reports of students near completion to the Academic Deans to identify potential graduates who may have course substitutions. The Deans will sign off on each student and send the report back. 3. Manually update all students submitted to the National Student Clearinghouse via Degree Verify whose graduation came back as G not applied. 4. Work with the National Student Clearinghouse to ensure the updates submitted are properly reflected in the student's enrollment history. Person Responsible Sandra Peterson, Registrar Projected Completion Date: January 21, 2020