Dunwoody College of Technology

National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: United States Department of Education Federal Program Name: Student Financial Aid Assistance Listing Number: Student Financial Aid Cluster Award Period: July 1, 2024 to June 30, 2025 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. Condition: During our testing, it was noted the College did not change the status timely for 9 out of the 40 students tested. Questioned Costs: None Context: Students did not have their enrollment status change updated timely. Cause: The College's current processes and controls did not ensure that student status changes were timely reported to NSLDS. Effect: The College did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes; 2024-003

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 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(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

ederal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Assistance Listing: Various Award Period: July 1, 2020 to June 30, 2021 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(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. There are two categories of enrollment information; Campus Level and Program Level, both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted the effective date reported on the ?Program Level? report in NSLDS was incorrect for 5 our of the 40 students tested. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Program Level effective dates. In the cases of these errors the enrollment information should have been the same for the Campus and Program Level. Cause: The enrollment roster file was pulling in dates that were not the effective date of the enrollment status. Effect: The College does not comply with Department of Education (ED) regulations relating to the reporting of student enrollment data to NSLDS. Repeat finding: Yes ? 2020-002 Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the Campus Level and Program Level. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Fund Assistance Listing: 84.425 Award Period: July 1, 2020 to June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that were suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: There were five vendors paid over $25,000. during testing of the vendor, it was noted there was no documentation to ensure the vendor was not suspended nor debarred at the time of purchase. In addition, there was no review of these vendors. Questioned costs: None Context: During our testing, we noted there was no documentation to ensure the vendor was not suspended or debarred. In addition, there was no documentation of review to ensure the vendor was not suspended or debarred. CLA noted that all five vendors were not suspended nor debarred. Cause: The control system to prevent payment to a suspended and barred vendor was not in place. Effect: The College could have paid a vendor who is suspended or barred at the time of purchase. Repeat finding: No Recommendation: CLA recommends documenting the vendor was checked on the SAM.gov website prior to payment. In addition, CLA recommends a supervisor to review the documentation prior to payment as a second review. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 001 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Various Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.164(l)(3) states that if a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition: Thirteen checks totaling $6,165 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2020. Questioned costs: $6,165 Context: During our audit procedures, it was noted there are thirteen checks totaling $6,165 related to student refunds of Title IV Federal financial aid that have been outstanding for more the 240 days. Cause: Management was not aware of the requirement to return checks that are not cashed within 240 days. Effect: The College is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 002 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Various Award Period: July 1, 2019 to June 30, 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(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted the effective date reported on the Program Level was incorrect for the 3 out of the 40 students tested. Questioned costs: None Context: The enrollment roster file contained dates that were incorrect for the Program Level. In the cases of these errors the enrollment information should have been the same for the Campus and Program Level. Cause: The enrollment roster file was pulling in dates that were not the effective date of the enrollment status. Effect: The College does not comply with Department of Education (ED) regulations relating to the reporting of student enrollment data to NSLDS. Repeat Finding: No Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the Campus Level and Program Level. Views of responsible officials: There is no disagreement with the audit finding.

FINDING: 2019 ? 001 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Various Award Period: 2018-2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires the College to report to NSLDS the correct Enrollment Status Effective Date, which is the date that the current enrollment status reported for a student was first effective. Condition: We noted 4 students out of 40 tested, had the incorrect effect date reported to NSLDS. Questioned costs: None Context: The correct effective date was not reported. Cause: The registrar had an incorrect Last Date of Attendance for the Students that withdrew during the add/drop period at the beginning of the term. Effect: Students have an incorrect effective date reported to NSLDS. Repeat Finding: No Recommendation: We recommend that the registrar and the student financial aid department work together to ensure they have the correct effective date of changes in status for each student. Views of responsible officials: There is no disagreement with the audit finding.

FINDING 2019 ? 002 Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid CFDA Number: Various Award Period: 2018-2019 Type of Finding: Significant Deficiency in Internal Control over Compliance 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 organization did not perform a risk assessment in the current year 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 documented safeguards for identified risks. Cause: The organization did not perform an IT Risk Assessment in the current year. Effect: 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. Repeat Finding: No Recommendation: We recommend the Organization perform a risk assessment which addresses all of the requirements in 16 CFR 314.4(b). Views of responsible officials: There is no disagreement with the audit finding.

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