Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.038/84.063/84.268/84.379/93.364 Federal Award Identification Number and Year: P007A241087 – 2025, P033A241087 - 2025 P063P240100 - 2025, P268K250100 - 2025, P379T250100 – 2025 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 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. Condition: The College did not correctly report student information to NSLDS in a timely manner. Questioned Costs: None Context: During our testing, we noted campus enrollment status for 6 of the 60 students tested was not reported timely to NSLDS, and enrollment status for 1 of the 60 students tested was not reported correctly. In addition, changes to campus enrollment effective dates for 2 of the 60 students tested were not reported timely to NSLDS. Further, program enrollment effective dates for 3 of the 60 students tested did not agree with institutional records, and program enrollment status for 4 of the 60 students tested was not reported correctly to NSLDS. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2024-001 Recommendation: We recommend that the College continue to implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the short time the Financial Aid Office has had direct oversight of this process, we have substantially reduced the number of incidents. Enrollment Reporting is a top priority. Like our colleagues at other Idaho institutions, we are striving to eliminate all issues with enrollment reporting. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals during the process by Registrar and Financial Aid staff, and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures have been updated to reflect all changes and validations. Additional focus will be on the reports that overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for corrective action plan: Immediate Implementation
2024-001
Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. Condition: The College did not correctly report student information in a timely manner. Questioned Costs: None Context: During our testing, we noted that the status change of 9 of the 60 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 1 of the 60 students tested. The credential level per NSLDS did not match the institutions records for 1 of the 60 students tested, and the enrollment change for campus and program enrollment did not match for 2 of the 60 students tested. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2023-001 Recommendation: We recommend that the College continue to implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office took over the administration of this process due to personnel changes in the Registrar’s Office this past year. During this time period, we have reduced the incidents from 114 to 13. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. Additional focus will be on the reports which overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff and John Bender Planned completion date for corrective action plan: Immediate Implementation
2023-001
Criteria or Specific Requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned Costs: None. Context: During our testing we noted one of forty students, from a statistically valid sample, were disbursed awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to the lack of a manual adjustment that was needed for this instance. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing 84.038 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was isolated to less-than-half-time Pell recipients. These recipients will be processed through the auto-packing process and then will undergo a secondary manual review prior to disbursement. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes and John Bender Planned completion date for corrective action plan: Immediate Implementation
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268/84.379/93.364 Federal Award Identification Number and Year: P268K230100 - 2023, P007A221087 - 2023, P063P220100 - 2023, P033A221087 - 2023, P379T230100 - 2023, E4C14916 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Material Noncompliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. Condition: The College did not correctly update student status changes and enrollment effective dates, nor did the College do so timely. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twenty eight samples for which the student’s enrollment status was not correctly reported to NSLDS, thirty samples for which the enrollment effective date was not correctly reported to NSLDS, twenty eight samples for which the change in status was not reported timely to NSLDS, and twenty eight samples for which the enrollment was not certified within 60 days. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with its third-party servicer and implement procedures to ensure that enrollment data, changes in status, and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Financial Aid Office has temporarily taken over the administration of this process due to personnel changes in the Registrar’s Office. Enrollment reports are scheduled to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. An internal audit will be conducted using the third-party Audit Guide and will be documented. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff, and John Bender Planned completion date for a corrective action plan: Immediate Implementation
2022-002
Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistant Listing Number: 84.038 Federal Award Identification Number and Year: N/A – Prior Perkins Awards Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 674.19.(e)(4)(iii), states that after the loan obligation is satisfied, the institution shall return the original or a true and exact copy of the note marked "paid in full" to the borrower, or otherwise notify the borrower in writing that the loan is paid in full, and retain a copy for the full prescribed period. Condition: The College did not retain a copy of the note marked “paid in full” in the records of the retired or assigned loans. Questioned Costs: None. Context: During our testing, we noted that the college did not retain a copy of the note marked "paid in full." for six of the ten retired or assigned loans tested. Cause: The College did not retain a copy of the note in the file. Effect: The College is not in compliance with the record retention requirements. Repeat Finding: No. Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation
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). This would include procedures to document a safeguard for risks identified in the risk assessment process for each of 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. Condition: The College did not identified safeguards for risks identified. Questioned costs: None Context: During our audit procedures, it was noted that the College performed a HEISC risk assessment; however, within the risk assessment there were no safeguards identified. Cause: Resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: Yes, 2021-003. Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College identify and document safeguards over risks identified in the risk assessment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of a formal initiative, college IT at LCSC led a college-wide evaluation with the goal of constructing a formal Risk Register. As risks are identified and formally assessed, mitigation strategies are being developed to ensure each identified risk has been properly mitigated. Name(s) of the contact person(s) responsible for corrective action: Marty Gang Planned completion date for corrective action plan: May 19, 2023
2021-003
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process for the 2021-2022 award year. Questioned costs: None Context: In our statistically valid sample of sixty students selected for NSLDS enrollment reporting testing, we identified twelve samples for which the student?s change in status was not properly updated within 60 days. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented for the 2021-2022 award year. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes, 2021-005 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to enhance the current process to ensure compliance and documentation of review process. The Registrar will formally document the review process for the initial reporting and all corrections submitted by the Assistant Registrar. The Financial Aid Team will expand the random review of select enrollment statuses and maintain documentation of such reviews. Name(s) of the contact person(s) responsible for corrective action: Soo Lee Bruce-Smith, Cheyenne Gaspar, Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: April 15, 2023
2021-005
Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62). The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student?s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The College under-awarded funds for the Pell Grant. Questioned costs: None. Context: During our testing we noted three out of forty-one students, from a statistically valid sample, were awarded less Pell than they were eligible for based on the 2021-22 Pell payment schedule. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: The College did not award the correct amount of the Pell grant due to human error when entering student's Cost of Attendance. Effect: Students did not receive the full amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Pell Program ? Assistance Listing No. 84.063 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the College disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This was a Pell error due to COA calculation and assignment error. Procedures will be implemented to review COA components to confirm accuracy of COA which will result in correct Pell awards. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender. Planned completion date for corrective action plan: Immediate
Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV (34 CFR 668.34(a)). A student on financial aid probation may receive title IV funds for one payment period. While a student is on financial aid probation, the institution may require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the student must meet the institution?s satisfactory academic progress standards or meet the requirements of the academic plan developed by the institution and the student to qualify for further title IV (34 CFR 668.34(8)(ii)). Condition: The College did not administer a Satisfactory Academic Progress (SAP) warning for one student that did not meet SAP requirements. Questioned costs: None. Context: During our testing we noted one out of forty-one students was not administered a SAP warning after falling under the requirement of maintaining at least a 2.0 cumulative GPA. Cause: The College?s Colleague ERP system incorrectly calculated the student?s cumulative GPA as being within requirements; however, the transcript ERP system showed the GPA to be below the required GPA.. Effect: Failure to properly track SAP requirements risks disbursing aid to students that may not be eligible to receive Title IV. Repeat Finding: No. Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College review its current procedures for tracking SAP requirements and implement procedures to ensure SAP status is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures will be implemented to select a random sample of students each term to confirm accuracy of SAP calculation. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Travis Osburn and John Bender Planned completion date for corrective action plan: 06/01/2023
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 180.300) requires that, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Condition: The College did not retain proper documentation for suspension and debarment verification. Questioned costs: None. Context: During our testing, we noted three out of five vendors tested did not have proper documentation for suspension and debarment verification. Cause: There are no procedures in place to routinely assess suspension and debarment for multi-year contracts with vendors, and inadequate maintenance of evidence the procedure occurred when suspension and debarment are assessed. Effect: Failure to assess suspension and debarment could lead to the College working with unqualified vendors. Repeat Finding: Yes, 2021-007. Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Views of responsible officials and planned corrective action: Management agrees with the finding and has developed a plan to correct it.
Education Stabilization Fund: COVID-19 HEERF Institutional Portion ? Assistance Listing No. 84.425F Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Manual procedures have been implemented to routinely check the suspension and debarment status for vendors who will be paid with grant funds. The initial manual procedure implemented did not include retaining evidence of the SAM.Gov suspension and debarment status verification when the verification resulted in no vendor record found. The manual procedure has been updated as of 03/27/2023 to include retaining evidence of the SAM.gov suspension and debarment status verification when no vendor record is found. PaymentWorks, a solution that will perform the suspension and debarment check automatically for all vendors, is in the process of being implemented, with a target date of July 2023. Name(s) of the contact person(s) responsible for corrective action: Jess Waddington Planned completion date for corrective action plan: 08/01/2023
2021-007
Criteria or specific requirement: The Code of Federal Regulations (34 CFR 674.42) requires an institution to ensure exit counseling is conducted with each borrower either in person, by audiovisual presentation, or by interactive electronic means. The institution must ensure exit counseling is conducted shortly before the borrower ceases at least half-time study at the institution. As an alternative, in the case of a student enrolled in a correspondence program or a study abroad program that the institution approves for credit, the borrower may be provided with written counseling material by mail within 30 days after the borrower completes the program. If a borrower withdraws from the institution without the institution?s prior knowledge or fails to complete an exit counseling session as required, the institution must ensure exit counseling is provided through either interactive electronic means or by mailing counseling materials to the borrower at the borrower?s last known address within 30 days after learning the borrower has withdrawn from the institution or failed to complete exit counseling as required. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure documentation is maintained after exit counseling notifications are sent out for each student. Condition: The College did not maintain exit counseling notifications. Questioned costs: None. Context: In our statistically valid sample of forty students selected for Eligibility testing, we identified ten samples for which exit counseling notifications were not maintained by the College. Cause: The College maintained records of the email which notified students about exit counseling requirements but did not track which students had been sent exit counseling notifications. Effect: The College was not in compliance with the exit counseling regulation to show evidence of notification to individual students. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all documentation is being maintained for students notified of exit counseling. Views of responsible officials: The College agrees with the finding.
Student Financial Aid Cluster: Federal Direct Student Loans ? Assistance Listing No. 84.268 Recommendation: We recommend the College implement procedures to ensure all documentation is being maintained for students notified of exit counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Process was modified in the Financial Aid Office. Notifications will be stored and tracked within Colleague. A communication management code will be added to the student?s record when the exit counseling information is sent to them. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Financial Aid Director Planned completion date for corrective action plan: Amended process was implemented for the 2021-2022 Award Year.
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). Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessment. 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 College did not perform a risk assessment 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 document safeguards for identified risks. Cause: According to LCSC officials, LCSC maintains information security policies and standards that address the provisions of the GLBA although resources have not been allocated to document a risk assessment related to students? information. Effect: The student personal information could be vulnerable. Repeat Finding: No. Recommendation: We recommend the College perform and document a comprehensive risk assessment identifying internal and external risks to the security, confidentiality, and integrity of the students? information. In addition, the College should ensure proper safeguards are in place to ensure the security of student information. Views of responsible officials: The College agrees with the finding.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Perkins Loan Program? Assistance Listing No. 84.038 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend the College perform and document a comprehensive risk assessment identifying internal and external risks to the security, confidentiality, and integrity of the students? information. In addition, the College should ensure proper safeguards are in place to ensure the security of student information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address the need to perform a risk assessment that addresses these three areas noted in 16 CFR 314.4 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 system failures and document safeguards for identified risks. By December 20, 2022, LCSC will have performed a penetration test through the Department of Homeland Security. LCSC State has partnered with the Statewide CyberDome project who will be providing IPS/IDS, intrusion protection system/intrusion detection system, system coverage for LCSC as well as performing a comprehensive risk analysis on an annual basis. In addition, LCSC is partnering with Boise State University to assist us with internal penetration testing and internal risk assessment. Human Resource Service (HRS) and Information Technology Services will partner and by June 2023 will document all technical and cybersecurity training provided through the college and State and in addition, the two departments will assess and identify needs for additional training. The risk assessments will address items 2 and 3 and the HRS/IT collaboration will address item 3. Name(s) of the contact person(s) responsible for corrective action: Marty Gang, Director of Information Technology and Vikki Swift-Raymond, Human Resource Services Director Planned completion date for corrective action plan: June 30, 2023 (training as the final piece)
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded aid within the prescribed limits and include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. Condition: The College lacked documentation of supervisory review of the R2T4 calculation. Questioned costs: None. Context: In our statistically valid sample of forty students, we did not note any noncompliance, but we noted all samples selected for R2T4 testing lacked documentation of supervisory review of the R2T4 calculation. Cause: R2T4 review procedures were in effect, but there was no formal documentation of the review to verify that it occurred for every student. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: No. Recommendation: We recommend that the College implement procedures to ensure review of R2T4 is documented. Views of responsible officials: The College agrees with the finding.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College implement procedures to ensure review of R2T4 is documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Process now includes a physical signoff on the calculation after review. This replaces the verbal review process. The calculation is performed by one staff member then reviewed and signed off by a second staff member. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Financial Aid Director Planned completion date for corrective action plan: Process was implemented for the 2021-2022 Award Year.
Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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. The Code of Federal Regulations, 34 CFR 682.610, also states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reported for both the Campus-Level and the Program-Level as well as the program begin date. When a student withdraws during a term (or, in a nonterm program, during a payment period), the effective date for the withdrawn (`W?) status is the withdrawal date used by the institution in accordance with 34 CFR 668.22(c). In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the `W? status is the final day of the term in which the student was last enrolled. The description within the National Student Loan Data System (NSLDS) Enrollment Reporting Guide (and compliance supplement) defines the Effective Date as: the date that the current enrollment status reported for a student was first effective. The important piece about the effective date is it starts the grace period for loans, so if a student is an unofficial withdrawal and the school uses 50% of the term for the return of Title IV (R2T4) calculation, then that date should be the effective date within NSLDS as well. Condition: The College did not update student status changes and enrollment effective dates timely, and there was no documentation to provide evidence of their review process. Questioned costs: None. Context: In our statistically valid sample of forty students selected for NSLDS enrollment reporting testing, we identified three samples for which the student?s change in status was not properly updated within 60 days. And we identified ten samples for which the student?s enrollment effective date was not properly updated. When uploading reports to the National Clearing House (NSC), the reports are reviewed and a spot check performed on student information. There is no evidence of this review documented. Cause: The College did not timely or properly report student status changes to NSLDS through their third-party servicer, National Student Clearinghouse (NSC). The enrollment effective date errors were related to human error and changes in staffing. There are no procedures in place to document supervisory review of the NSLDS reporting process. Effect: Failure to properly report withdrawal dates on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: No. Recommendation: We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Views of responsible officials: The College agrees with the finding.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine enrollment reports are submitted by the Assistant Registrar and reviewed by the Registrar. Any error reports received are reviewed and processed by the Assistant Registrar and any corrections are submitted after review by the Registrar. Updates for withdrawals are submitted by the Assistant Registrar and a random selection is reviewed by the Associate Director of Student Relations in the Financial Aid Office. Registrar will send an email to the Assistant Registrar when review is complete. Emails will be the documentation of additional review. This will be the quality control documentation for routine and correction submissions. Associate Director of Student Relations will record date of review and which student was reviewed within the withdrawal spreadsheet. This will be the documentation for quality control purposes. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes ? Financial Aid Director, Soo Lee Bruce-Smith- Director of Admissions, Cheyenne Gaspar ? Assistant Registrar, and Travis Osburn ? Asst. Director for Student Relations Planned completion date for corrective action plan: Additional reviews and random checks were implemented for the 2021-2022 Award year, but with verbal confirmations. The physical documentation for these checks has been implemented for the 2022-2023 Award year.
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure G5 drawdowns are formally reviewed by a supervisor who did not prepare the drawdown to verify the correct amount is requested. Condition: The College lacked documentation of supervisory review cash management procedures. Questioned costs: None. Context: In our statistically valid sample of eight drawdowns, we noted that all samples selected for cash management testing lacked documentation of supervisory review. Cause: There are no procedures in place to document supervisory review of G5 drawdowns. Effect: Failure to properly review cash management drawdowns could result in an improper amount of funds being requested. Repeat Finding: No. Recommendation: We recommend that the College implement formal review procedures to document that the G5 drawdown reviews are being performed to minimize the likelihood of errors going undetected in a timely manner. Views of responsible officials and management?s response: The College agrees with the finding.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant ? Assistance Listing No. 84.007 Federal Work Study Program ? Assistance Listing No. 84.033 Federal Pell Grant Program ? Assistance Listing No. 84.063 Federal Direct Student Loans ? Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants? Assistance Listing No. 84.379 Nursing Student Loans ? Assistance Listing No. 93.364 Recommendation: We recommend that the College implement formal review procedures to document that the G5 drawdown reviews are being performed to minimize the likelihood of errors going undetected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Controllers Office- Treasury Management employees will initiate a workflow process to request a G-5 drawdown using backup from Student Affairs offices. The backup, of which will be documented, will be reviewed, balanced and approved by the Senior Accounting Technician before the transaction is initiated in G-5. Before the G-5 drawdown is transacted, a Manager, Controller or Vice President will review and approve the G-5 transaction and this review will be documented. These steps will begin implementation in October and will be refined up through December 31, 2022. Name(s) of the contact person(s) responsible for corrective action: Mark McNabb, Controller Planned completion date for corrective action plan: December 31, 2022
Criteria or specific requirement: Uniform Grant Guidance (2 CFR 180.300) requires that, when entering into a covered transaction with another person (an individual, corporation, partnership, association, unit of government, or legal entity), you must verify that the person with whom you intend to do business is not excluded or disqualified. Condition: The College retain proper documentation for suspension and debarment verification. Questioned costs: None. Context: During our testing, we noted two samples out of two vendors tested did not contain proper documentation for suspension and debarment verification. Cause: There are no procedures in place to routinely assess suspension and debarment for multi-year contracts with vendors, and inadequate maintenance of evidence the procedure occurred when suspension and debarment are assessed. Effect: Failure to assess suspension and debarment could lead to the College working with unqualified vendors. Repeat Finding: No. Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Views of responsible officials and management?s response: The College agrees with the finding.
Education Stabilization Fund: COVID-19 HEERF Institutional Portion ? Assistance Listing No. 84.425F Recommendation: We recommend the College implement formal procedures to routinely assess suspension and debarment status for vendors used in multiple years, and we recommend that assessment of suspension and debarment status be retained to support evidence the procedure was performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: LC will develop a formal procedure and/or implement a software technology program to ensure that vendors are assessed no less than annually for suspension and debarment and will document this review. In the immediate term, vendor payments using federal grant funds will be individually assessed and this assessment will be documented. Name(s) of the contact person(s) responsible for corrective action: Jessica Waddington, Interim Purchasing Director Planned completion date for corrective action plan: Immediate implementation with a finalization date anticipated in January 31, 2023
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