Jefferson Hospital Association, Inc.

Sudent Financial Assistance Cluster Federal Pell Grant Program, ALN 84.063; Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – NSLDS Reporting (34 CFR 690.93(b)(2); 34 CFR 682.610; 34 CFR 685.309). Institutions are required to report enrollment information. Condition – Student enrollment information was not submitted to the National Student Loan Data System (NSLDS) during the fiscal year. Cause – The institution’s internal controls did not ensure student enrollment information was reported timely and accurately. Effect or Potential Effect – Enrollment information was not reported to NSLDS. Questioned Costs – None Context – The Association did not complete required NSLDS submissions during the fiscal year. Identification as a repeat finding – N/A Recommendation – The Association should update internal controls to ensure students’ enrollment status is reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions – Responsible Official: Michelle Newton RN-Director JRSON Planned Corrective Actions: The Financial Aid Coordinator of JRSON will update the rosters to accurately reflect the status of students in the nursing program. The Financial Aid Coordinator will update the rosters monthly. The Financial Aid Coordinator is seeking to contact The National Student Clearing House regarding enrollment reporting.

Student Financial Assistance Cluster Federal Pell Grant Program, ALN 84.063; Federal Direct Student Loans, ALN 84.268 U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – The Gramm-Leach-Bailey Act (16 CFR 314) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 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-Bailey Act (GLBA) because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi)). Institutions agree to comply with the GLBA in their Program Participation Agreement with the Department of Education (ED.) Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition – The Association must have a written information security program that addresses the required minimum eight elements. Cause – The Association’s controls did not ensure the revised GLBA regulations were implemented by the required date. Effect or Potential Effect – The Association did not implement the revised GLBA regulations by the required date. Questioned Costs – None Context – The Association does not have a written information security program that addresses the required elements. Identification as a Repeat Finding – N/A Recommendation – The Association should complete the written information security program and ensure the additional required GLBA elements are included. Views of Responsible Officials and Planned Corrective Actions – Responsible Official: Michelle Newton, Director of Jefferson Regional School of Nursing Planned Corrective Actions: Jefferson Regional School of Nursing (SON) will take the necessary steps to become compliant with requirements contained in the Gramm-Leach-Bailey Act including creating the information security program that addresses the required minimum eight elements.

GSA_MIGRATION