Centenary College of LouisianaHigher Education

Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The College’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct. Questioned costs - $0 Context – Out of the population of 18 students who withdrew during the year and were awarded federal aid, 3 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. The amount calculated to be returned for one student due to their withdrawal was incorrect. Effect – More Title IV funds were returned to the U.S. Department of Education than required. Cause – The College’s internal controls did not ensure the calculated amount to be returned was correct. Identification of repeat finding, if applicable – 2023-001 Recommendation –The College should update their controls to ensure each calculation of funds to be returned is correct. Views of responsible officials and planned corrective actions – The Financial Aid Director is responsible for the return of federal funds. The college’s ERP system calculates the return amounts. Although there was no error in the calculation the $6.00 due to the college was returned to the Department of Education. See separate report for planned corrective actions.

Criteria or specific requirement – Reporting – According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13, and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in timely and accurate manner. Condition – Cost of attendance per the College’s system did not agree with the reported cost of attendance reported per COD records. Questioned costs - $0 Context – Out of the population of 502 students who received $6,223,012 of federal aid, a sample of 25 students who received $290,966 of federal aid were selected. Of the 25 students selected, the College reported cost of attendance incorrectly for 2 students’ Pell awards. Our sampling method was not, and was not intended to be, statistically valid. Effect – The College did not report accurate data to COD. Cause – Lack of detailed reconciliation of student origination records to data provided to COD. Identification of repeat finding, if applicable – N/A Recommendation –The College should review and update its processes for reporting information to COD. Views of responsible officials and planned corrective actions – The Financial Aid Director establishes aid budgets for various student groups. These budgets are entered in the college’s ERP system and a Pell origination record is established and sent to COD. A previous upgrade that seems to have only affected students enrolled in one term caused a difference in the COA and COD database. This defect has been resolved with the recent upgrade. See separate report for planned corrective actions.

Criteria or specific requirement – Special Tests and Provisions – Return of Title IV Funds (34 CFR 668.22(a)(1) through (a)(5) Condition – The College’s internal controls did not ensure the calculation of amounts to be returned to the U.S. Department of Education were correct and were performed timely. Questioned costs - $0 Context – Out of the population of 21 students who withdrew during the year and were awarded federal aid, 3 were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. Total days in the semester for one of the withdrawals tested was calculated incorrectly and the withdrawal date that was used for one student was incorrect. Effect – More Title IV funds were returned to the U.S. Department of Education than required. Cause – The College’s internal controls did not ensure proper identification of withdrawal dates for unofficial withdrawals, nor did they ensure proper inputting of semester information into the calculation of returns of Title IV funds based on total days in the semester and total days attended. Identification of repeat finding, if applicable – N/A Recommendation –The College should update their controls to ensure that the total days in the semester are calculated correctly based on proper identification of withdrawal dates for unofficial withdrawals and total days attended by students are calculated correctly. Views of responsible officials and planned corrective actions – This finding is in reference to an R2T4 miscalculation for a graduate student enrolled in our MBA Program for the 2022-23 academic year. BACKGROUND: The Financial Aid Director has historically been the person to input semester/session beginning and ending dates into our CRM system (Banner ERP). The reason for this is because the financial aid office needs these exact dates in the system at least six months before any other department needs them. EXPLANATION: The MBA Program consists of five, 10-week sessions in an academic year. Since the inception of this program, the beginning and end dates of these sessions have been the same (within a few days). In particular, the “Winter I” session dates have historically started around the middle of October and ended the first week of January. It seems that the MBA Program Director decided to change the end date of this particular session from the first week of January to the third week of December for the 2022-23 academic year. The Financial Aid Director did not receive a communication of this change. It was included in the 2022-23 MBA Catalog. Entering the incorrect ending date for this session was the error of the Financial Aid Director. PLANNED CORRECTIVE ACTION: The Financial Aid Director will no longer enter the dates of semesters/sessions in the Banner ERP system. The Registrar will assume responsibility for this task and work in conjunction with directors of Financial Aid and the MBA program to ensure term dates are established when needed and accurately maintained.

Criteria or specific requirement – Special Tests and Provisions – Gramm-Leach-Bliley 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-Bliley 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 GLBA in their Program Participation Agreement with 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 College must have a written information security program that addresses the required minimum seven elements. Questioned costs - $0 Context – The College is in the process of performing a risk assessment that will be used to generate the written information security program. The College has designated their Chief Information Officer as the qualified individual responsible for implementing and monitoring their information security program. They have started addressing the additional six required elements, including reviewing access controls, implementing multi-factor authentication for students, disposing of student information securely, and performing annual penetration testing but they are still in the process of reviewing the log for unauthorized access, implementing multi-factor authentication for staff and faculty with access to student information, implementing policies and procedures to ensure that personnel are able to enact the information security program and encrypting all information on the institution’s system and when it’s in transit. Effect – The College did not implement the revised GLBA regulations by the required date. Cause – The College’s controls did not ensure the revised GLBA regulations were implemented by the required date. Identification of repeat finding, if applicable – N/A Recommendation –The College should complete the risk assessment and implement a written information security program and ensure the additional six required GLBA elements are included in the program. Views of responsible officials and planned corrective actions – The College will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY24 and in full compliance by the end of FY25. The college will prioritize key elements such as reviewing access controls, implementing multi-factor authentication for the campus, disposing of student information securely, performing annual penetration testing, and encrypting all the institution's information.

COVID-19 ? Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 Criteria or specific requirement ? Procurement 2 CFR 200.320 Condition ? The College charged services to the institutional portion of the award that had not been procured. Questioned Costs ? ALN 84.425F - $32,061 ? Questioned costs include amounts charged to the grant for an existing contract that was not procured after the Louisiana State of Emergency for COVID-19 ended, so the noncompetitive procurement method no longer qualified. Context ? Out of $210,105 expenses that were charged to the institutional portion of the grant and were above the College?s micro-purchase threshold, 3 key items of contracts totaling $166,574, were selected for testing. Of the contracts tested, one contract was not procured in accordance with the Uniform Guidance. When the contract was originally entered into, it was not paid for with federal funds, so the College wasn?t required to follow the procurement guide lines. At the start of the pandemic, the contract was expanded to be able to provide on-line instruction, and therefore the College used the noncompetitive procurement option given the public exigency and emergency circumstance that would not permit a delay resulting from publicizing a competitive solicitation. The Louisiana State of Emergency ended in March 2022 and the College did not have a plan in place to procure the services after noncompetitive procurement flexibility ended. Effect ? Expenses were charged to the grant that were not procured in accordance with the Uniform Guidance. Cause ? The College did not follow their procurement policy for expenses charged to federal awards. Identification of repeat finding, if applicable ? N/A Recommendation ? Management should review contracts being charged to federal grants to ensure they have followed their procurement policy. Views of responsible officials and planned corrective actions ? The College concurs with the finding and recommendation and will review contracts supported by federal grants to ensure they meet institutional and federal guidelines. The College will also review our current procurement policies and make any adjustments that may be necessary.

Criteria or specific requirement ? Eligibility ? Must maintain good standing, or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11, 20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)) Federal Direct Loans have annual loan limits that vary based on the student?s grade level and dependency status. (34 CFR 685.203). Condition ? The College did not place students on suspension for not maintaining satisfactory academic progress during Spring 2020 and Fall 2020. Additionally, the College?s controls did not ensure Federal Direct Student Loans limits were followed. Questioned costs ? $14,250 ? Assistance Listing Number 84.268 Context ? Out of the population of 421 students who received federal financial aid, a sample of 25 students were selected for testing. Our sampling method was not, and was not intended to be, statistically valid. One student tested dropped below the required GPA after the Spring of 2020 and should have been placed on probation during the Fall 2020 according to the College?s satisfactory academic progress policy (SAP). The student also failed to meet the SAP requirements during the Fall of 2020 and should not have been able to receive federal financial aid during Spring 2021 but was awarded $13,250. Additionally, a student was awarded federal direct student loans that exceeded the limit based on the student?s grade level by $1,000. Effect ? Students were awarded federal financial aid that were not eligible. Cause ? The College?s controls did not ensure students were awarded based on the federal direct student loan limits. Additionally, the College misinterpreted the flexibilities allowed by the CARES Act as it related to SAP. Identification as repeat finding, if applicable ? N/A Recommendation ? The College should update their controls to ensure students are only awarded federal financial aid if they are eligible.

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