Clatsop Community College

Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In cases where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College had outstanding Title IV Federal Student Aid (FSA) checks issued to students that remained unclaimed for more than 240 days from the date of issuance. Questioned Costs: None Context: During testing of outstanding Title IV–funded checks, we identified three checks that exceeded 240 days from the date of issuance and had not been returned to the U.S. Department of Education. Cause: The College’s existing processes do not adequately monitor outstanding Title IV–funded checks to ensure timely identification and return of unclaimed funds. Effect: As a result, the College is not in compliance with federal requirements related to the return of unclaimed Title IV–funded checks issued to students or parents. Repeat Finding: Yes, 2024-003 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office provides a list monthly of the uncashed financial aid checks to the Financial Aid Office. The Financial Aid Office is contacting the students to remind them to cash their checks. The funds for the uncashed checks are returned to the College after 90 days and then returned to the source of the funding. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla and Layla Solar. Planned completion date for corrective action plan: Already implemented.

2024-003

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. 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. 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. In addition, 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. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 23 students where the campus enrollment status was not reported correctly, 21 students where the enrollment effective date was not reported correctly, 37 students where the enrollment was not reported timely to NSLDS, and 56 students where enrollment was not certified every 60 days. There was also no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institution’s records in a timely manner. 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, 2024-004 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of Responsible Officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An Ellucian consultant provided us with customized process documentation for our new SIS (Ellucian Colleague) which is saved in a shared drive to ensure consistency in the process. The Interim Dean of Students / Financial Aid Director is currently completing the reporting with our Director of Institutional Research receiving the reports and verifying completeness through National Student Clearinghouse, ensuring that there is an internal control. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Ian Wilson Planned completion date for corrective action plan: Implemented

2024-004

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: During our eligibility testing, we identified that 2 out of 38 students who received Pell grants were over awarded and overpaid. The explanation provided indicated that the system packages Pell awards based on the annual award, divides it to calculate per-term disbursements, and then rounds the amounts up or down. CLA recalculated the awards using the annual award and found that the system was incorrectly rounding up, resulting in the over awards. Questioned Costs: None Context: During our eligibility testing of thirty-eight students who received Pell, we noted two students that were over awarded and overpaid in Pell grants. Cause: The software that is used to auto package Pell awards has rounding rules inconsistent with that of the rules outlined in the Federal Student Aid handbook and was rounding amounts up when then it should have been rounded down. Effect: A student received more aid than they were eligible for. Repeat Finding: No. Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Views of responsible officials: There is no disagreement with the finding.

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated 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: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

Criteria or specific requirement: 2 CFR part 200 section 200.303 requires that non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the federal award. The Code of federal Regulations, 34 CFR 688.164, requires any Title IV federal funds disbursed to a student or parent that are not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. If a check or an EFT is returned, the College may make additional attempts to deliver the funds, provided that those attempts are made no later than 45 days after the funds were returned or rejected. In case where the College does not make another attempt, the funds must be returned before the end of the initial 45-day period. The College must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. Under no circumstances may unclaimed Title IV FSA funds escheat to the state, or revert to the college, or any other third party. Condition: The College does not have a control or process in place that would specifically monitor outstanding checks to students for Title IV federal funded checks so that the College would be able to timely return the money prior to 240 days after issuance of the check. Questioned Costs: None Context: During our testing, it was noted the College did not have a control in place to identify the outstanding Title IV federal funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. During our testing of outstanding checks, we did not note any checks that were out of compliance with this requirement. Cause: The College did not have a process in place to specifically monitor the federal checks throughout the year. Effect: The College is not in compliance with Department of Education requirements. Repeat Finding: No. Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Views of responsible officials: There is no disagreement with the audit finding.

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024

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. 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. 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. In addition, 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. Condition: There were instances in which the College did not report the correct status and effective dates, enrollment was not certified timely, and the status changes were not always reported timely. In addition, the College did not have a control in place to ensure timely and accurate reporting to NSLDS. Questioned Costs: None Context: In our statistically valid sample of sixty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 4 students where the campus enrollment status was not reported correctly, 6 students where the enrollment effective date was not reported correctly, 57 students where the enrollment was not reported timely to NSLDS, and 60 students where enrollment was not certified every 60 days. There was no control in place to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify students' status in NSLDS matched the institutions records in a timely manner. 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, Prior year finding 2023-004. Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Views of responsible officials: There is no disagreement with the audit finding.

Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025

2023-004

Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 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)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: Yes. Prior year finding 2023-005. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working on an updated WISP and plan to have it approved by college administration prior to the end of the academic year. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: 6/30/2025

2023-005

Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: The College did not provide the URL for the contract or cost information to the Department of Education. Questioned Costs: None Context: The College did not meet the compliance requirement to report the URL for the contract and cost information to the Department of Education. Cause: The College did not have proper procedures in place to ensure that all requirements were being met. Effect: The College is not in compliance with disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: Yes, Prior year finding 2023-006. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.

Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no longer using a Tier One processor for our financial aid refunds. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented July 2024 when we changed from Bank Mobile to TouchNet.

2023-006

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Loans Federal Award Identification Number and Year: P268K220355 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203 specifies the annual and aggregate loan limits the Institutions may not exceed for an academic year of study under the Direct Loan program and also requires loans to be prorated for a program of student that is less than a full academic year in length. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College over paid federal direct loans. Questioned Costs: None Context: During our eligibility testing of 40 students, we noted one student had a subsidized loan over payment due to reaching their subsidized aggregate loan limit. Cause: When doing the award packaging for this student, the College did not adjust award amounts based on the student’s subsidized aggregate loan limit activity. Effect: The institution paid this student an amount of subsidized loans that was above the subsidized aggregate loan limit. Repeat Finding: No. Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is now appropriately staffed and extra time will be taken to ensure NSLDS is being reviewed prior to loan origination. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleysne & Layla Solar Planned completion date for corrective action plan: Completed

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. 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. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted the College did not update student status changes and enrollment effective dates correctly or timely. Questioned Costs: None Context: During our sample test of 19 students, we noted:  17 students’ enrollment status on NSLDS differed from the College’s records.  17 students’ status change was not reported timely.  16 students’ enrollment effective dates on NSLDS differed from the College’s records.  The enrollment was not certified at least every 60 days for 19 students. Cause: The College did not have proper procedures in place to verify that student and enrollment status changes in NSLDS matched the institutions records, nor were status changes updated in a timely manner. 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. See prior year finding 2022-006 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25

2022-006

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Compliance, Other Matter. Criteria or specific requirement: The Gramm-Leach-Bliley Act (Pub. L. No. 106-102) (GLBA) 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 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)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College does not have an updated written information security program (WISP) to reflect the current practices that address the required components outlined in the GLBA Safeguards Rule. Questioned Costs: None Context: During our testing, we noted the College has procedures in place for the required elements identified, however, the College does not have an updated WISP that meets the compliance requirements outlined in the GLBA Safeguards Rule. Cause: The College is drafting the necessary IT policies, and they were not in place at the time of testing. Effect: The College is out of compliance with GLBA requirements because they do not have a written information security plan, formal change management policy, and formal vendor management policy in place. Repeat Finding: No. Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity 84.268 – Federal Direct Loans 84.007 – Federal Supplemental Educational Opportunity Grants 84.033 – Federal Work Study Program Federal Award Identification Number and Year: P063P210355 - 2023, P268K220355 - 2023, P007A213474 - 2023, P033A213474 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent, to issue a check payment to the student or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. Additional guidance on Tier One and Tier Two arrangements can be found in Dear Colleague Letter GEN-22-14; Volume 4, Chapter 2 of the FSA Handbook; and the Cash Management Q&A. These schools must take affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements for these arrangements are met with respect to all accounts offered pursuant to the arrangement (34 CFR 668.164(e)(2)(x) and (f)(4)(ix)). In addition, per Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that the College did not post required third-party servicer information to the website, nor did they provide the URL for the contract or cost information to ED. Questioned Costs: None Context: During our testing of 8 out of 32 students who have an account with the College’s third-party servicer, we noted the College did not post the third-party servicer's contract to the website, nor did they provide the URL for the contract to ED. Additionally, the required cost information was not on the website, nor was it updated within 60 days after the end of the award year, nor was the URL for the cost information provided to ED. Cause: The College did not have procedures in place to ensure that all requirements were being met. Effect: The College did not meet disclosure requirements of a Tier One arrangement with a third-party servicer. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for a third-party servicer are being met. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Loans Federal Award Identification Number and Year: P268K220355 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria or specific requirement: Per the 2022-2023 FSA Handbook Volume 4 Chapter 6, A school that participates in the Direct Loan Program is required to reconcile cash (funds it received from the G5 system to pay its students) with disbursements (actual disbursement records) it submitted to the Common Origination and Disbursement (COD) system monthly. In addition, per the Uniform Guidance 2 CRF 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not perform monthly direct loan reconciliations and reconciliations were not reviewed by someone other than the preparer. Questioned Costs: None Context: During our testing, we noted that the College did not perform one of three reconciliations selected for testing, and the College could not provide support for review performed of the other two of the three reconciliations selected for testing. Cause: The College started but never finished or saved the missing direct loan reconciliation. In addition, the College did not set up procedures to include review of the reconciliation. Effect: The College is not in compliance with the requirement to perform monthly reconciliations and establishing and maintaining good internal controls. Repeat Finding: No. Recommendation: We recommend the College implement procedures to ensure direct loan reconciliations are performed monthly and are reviewed by someone other than the preparer. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is aware of the requirement to perform direct loan reconciliation. We are now appropriately staffed with monthly reconciliation being performed by the Assistant Director and being sent to the Director of Accounting for review. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Layla Solar Planned completion date for corrective action plan: Completed

Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) 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). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: In our testing, we noted an instance in which the College could not provide evidence the student received a SAP warning. Questioned Costs: None Context: During our testing we noted 1 of the 40 students tested did not have documentation available supporting that the student received SAP warning when they were not meeting SAP. The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Cause: The student's prior term was in 2017-2018 when the college used a different software, and student's SAP warning did not carry over into the new software. Effect: Students could have received aid that were not meeting SAP. In this situation, the student was eligible to receive aid in the following terms. Repeat Finding: Yes. See prior year finding 2021-004 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SAP policy has been updated to include only classes taken under current major to better work within system limitations. Staff will run SAP manually on students with prior attendance in legacy system. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

2021-004

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). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: For one student, the College under awarded Pell. Questioned Costs: None Context: In our testing, we noted that 1 of the 38 students tested that received Pell, was under awarded based on their expected family contribution (EFC) and enrollment status. Cause: It was noted that the new software used to prepare the student award packages had errors in the disbursement schedule that was used to determine the Pell awards. Effect: One student was under awarded Pell Grant. Repeat Finding: Yes. Prior year Finding 2021-005. Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063 Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director and Assistant Director will test the first 40 Pell awards of each academic year to ensure the Pell tables are accurate. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: June 1, 2023

2021-005

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 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 30 students tested was not reported correctly to NSLDS. The enrollment effective date of 8 of the 30 students tested was not reported correctly to NSLDS. The status change of 8 of the 30 students tested was not reported timely to NSLDS. The program begin date of 2 of 30 students tested did not agree to the program begin date per NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2021-006. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A request for additional staffing due to the systems limitation has been submitted. Financial Aid will provide the registrar with the list of students who have aid so they can review those students in NSLDS and not rely on the clearinghouse. Name(s) of the contact person(s) responsible for corrective action: Siv Serene Barnum Planned completion date for corrective action plan: June 30, 2023

2021-006

Criteria or specific requirement: The institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student?s right, or parent?s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check (34 CFR 668.165). In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: We tested notifications of loan disbursements and noted only a general notification of disbursements went out stating the date that funds were anticipated to be disbursed to student accounts in general. The required elements of the notification of disbursements were not met by this blanket notification. Questioned Costs: None Context: In our testing, we noted that seven of the seven students tested that receive Loans did not receive a notification of disbursements. Cause: The College did not send award disbursement notifications to students at the time of the loan disbursement. Effect: The College was not in compliance with the requirement to provide notification to a student when their loan disbursement is made. Repeat Finding: No. Recommendation: We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA Handbook. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all of the required elements outlined in the FSA Handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is drafting a disbursement notification that will be emailed by the business office at the time of loan disbursement. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: June 1, 2023

Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include a documented formal review to ensure the accuracy of all Return of Title IV (R2T4) calculations. The FSA Handbook provides guidance and a form on how the R2T4 calculation is to be calculated, applied to disbursements made, and timeline for returning any required return. Condition: There was an instance when the College did not correctly calculate the return of title IV funds (R2T4) and submit the payment timely. In addition, the College did not have observable controls to test over the return of title IV (R2T4) calculations. Questioned Costs: None Context: During our testing, we noted 1 of the 8 students tested for R2T4 was incorrectly calculated, incorrectly applied, and credited to the Department of Education more than 45 days after it was determined the student withdrew. We also noted that all 8 samples lacked documentation of review of Refund of Title IV aid calculation. Cause: The new software made it difficult to make sure calculations were correct and reviewed. Effect: The College was not in compliance with how the R2T4 calculation was prepared and submitted. It is possible for errors to occur and not be caught in a timely manner when there isn?t a documented review process. Repeat Finding: Yes. Prior year finding 2021-007 and 2021-008 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the process be put in place to ensure the calculation of the R2T4 is done correctly and that all calculations are reviewed and such review is documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All R2T4 calculations are now being performed in COD. All calculations are being reviewed by a second staff member. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed.

2021-007

Criteria or specific requirement: Under 24 CFR 668.164, an institution must return to the U.S. Department of Education, any Title IV funds that it attempts to disburse directly to a student or parent that are not received by the student or parent. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made no later than 45 days after the EFT was rejected or the check returned. In cases where the College does not make another attempt, the funds must be returned to the U.S. Department of Education before the end of this 45-day period. If a check is sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the U.S. Department of Education no later than 240 days after the date it first issued the check. In addition, per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: In our testing, we noted checks that should have been returned to the U.S. Department of Education. Questioned Costs: None Context: In our testing, we identified 3 outstanding checks payable to students for Title IV awards that were not returned to the Department of Education within the 240 day prescribed timeframe. Cause: The College?s policies and procedures did not ensure compliance with the applicable criteria. Effect: The checks identified resulted in noncompliance with the Title IV regulation. Repeat Finding: No. Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Views of responsible officials: There is no disagreement with the audit finding.

Student Financial Assistance Cluster ? Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College update its procedures for processing and monitoring outstanding checks to students, to ensure compliance with the Title IV requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff is being trained to monitor all outstanding checks and to follow the federal and state guidelines. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: June 30, 2023

Criteria or specific requirement: Compensation for personal services charged to a grant should be for employees engaged in work on that federal program. Condition: During our testing of payroll disbursements for this program, we noted one payroll disbursement was charged to the grant in error. Questioned Costs: $2,270 Context: During our testing, we noted 1 out of 5 payroll disbursements was charged to the grant in error. Cause: The employee's time was incorrectly coded to the grant and was not caught in the program manager?s review. Effect: The College charged salaries and benefits to the grant that were unallowed costs. Repeat Finding: Yes. Prior year finding number was 2020-004. Recommendation: We recommend the College return the funds for the unallowed costs. We also recommend a process be put in place to ensure that all payroll costs charged to the grant and paid with federal funds are allowable. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend the College return the funds for the unallowed costs. We also recommend a process be put in place to ensure that all payroll costs charged to the grant and paid with federal funds are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A change in personnel responsible for ensuring that all grant payroll is posted according to the time and effort reports turned in by the grants each month has occurred. The former Director of Accounting has returned. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla, Director of Accounting Planned completion date for corrective action plan: Completed

2020-004

Criteria or specific requirement: The College must establish a reasonable satisfactory academic progress (SAP) 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). Condition: In our testing, we noted instances in which students did not receive SAP warning or probation letters when they were not meeting SAP and an instance when a student incorrectly continued to receive Title IV aid after not meeting SAP for two terms. Questioned Costs: None Context: During our testing, we noted 2 of the 40 students tested did not receive SAP warning or probation letters when they were not meeting SAP. One of the students continued to receive Title IV aid after not meeting SAP for two terms, without any communication from the College or appeal from the student. Cause: The College does not have a process in place to communicate to students when they are not meeting SAP. Effect: Student received aid that was not meeting SAP. In this situation, the student was ineligible to received title IV aid. Repeat Finding: No Recommendation: We recommend a process be put in place to ensure all students not meeting SAP are communicated with. A letter should go to the student appropriately communicating financial aid warning and financial aid probation. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend a process be put in place to ensure all students not meeting SAP are communicated with. A letter should go to the student appropriately communicating financial aid warning and financial aid probation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A review of the CCC SAP process has been conducted and deficiencies have been identified. The Anthology integrated system, which is used to identify, review and process SAP has been configured to review SAP in accordance with ED guidance. The system has not been working with the SAP process correctly. Intensive work with the vendor, the CCC Registrar and financial aid staff have been conducted in an attempt to isolate system deficiencies. The SAP process will be manually reviewed by CCC staff at the end of each term to ensure that the correct students are identified and SAP is applied correctly to each student. Communication to students about all aspects of the SAP process have been reviewed to ensure they are timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse, Director of Financial Aid Planned completion date for corrective action plan: The manual review of all aspects of the SAP process is now being conducted and will be on an ongoing basis.

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). Condition: For some students, the College under awarded Pell. Questioned Costs: None Context: In our testing, we noted that 3 of the 48 students tested that received Pell, were under awarded based on their expected family contribution (EFC) and enrollment status. Cause: It was noted that the new software used to prepare the student award packages had errors in the disbursement schedule that was used to determine the Pell awards. Effect: Students were under awarded Pell Grants. Repeat Finding: No Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that a process be put in place to test the software system prior to doing award packages to ensure that the Pell award for all students is calculated correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Deficiencies in the Anthology system Pell Grant 2020-21 awarding process have been identified. Pell Grant ?tables? for the 2020-21 award year were not entered by the vendor into the system correctly. Problems with Pell Grant amounts were observed by CCC staff during the monthly reconciliation process. CCC financial aid staff have been manually reviewing Pell Grant awards for compliance with correct Pell Grant amounts. The system vendor has been contacted and problems with the Pell Grant tables identified. Testing of the Anthology system and its awarding of Pell Grants is being done before the start of the award year and during the award cycle. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse, Director of Financial Aid Planned completion date for corrective action plan: Review of all financial aid activities related to the awarding and disbursement of PELL Grant funds is now being conducted and will be on an ongoing basis.

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 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the National Student Loan Data System (NSLDS) enrollment reporting edits. Condition: There were instances in which the College did not correct and resubmit the National Student Loan Data Systems (NSLDS) rosters timely. There were also instances in which the College did not report the correct status and effective dates and status changes were not always reported timely. Questioned Costs: None Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 2 of the 40 students tested was not reported correctly to NSLDS. The enrollment effective date of 5 of the 40 students tested was not reported correctly to NSLDS. The status change of 14 of the 40 students tested was not reported timely to NSLDS. The enrollment was not certified every 60 days for 9 of the 40 students tested. The program enrollment effective date of 4 of the 40 students tested was not reported correctly to NSLDS. 1 of the 40 students tested received federal student aid but was not reported to NSLDS. Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were responded to within the 10-day requirement. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes. Prior-year finding number was 2020-001. Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of last year?s audit CCC has reviewed and modified its process involving error updating and added additional staff to work with NSC/NSLDS errors. The additional staff have been trained and have been working with the error resolution process. The CCC institutional data system Anthology generates reports that at times are not compatible with the NSC upload process. Most error reports contain hundreds of students. A manual review of student data is being done to ensure compatibility and completeness. The review process is extremely labor-intensive time consuming. The enrollment status of the students in question has been has been corrected in NSLDS. The enrollment effective date has been properly reported to NSLDS for the students in question. The status change in the students tested has been reviewed and corrected, if necessary in NSLDS. The program enrollment effective date has been reviewed and corrected in NSLDS. The student not reported to NSLDS has been added. The institutional system provider, Anthology has been actively engaged to resolve NSC/NSLDS report issues. A resolution has not been arrived at. CCC has established internal working deadlines to resolve error review and updating. The internal process efficiency is dependent upon the number of errors needing to be resolved. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum, Registrar Planned completion date for corrective action plan: A review of all activities related to NSC/NSLDS reporting has been conducted and will be monitored on an ongoing basis.

2020-001

Criteria or specific requirement: An institution must document a student's withdrawal date and maintain the documentation as of the date of the institution's determination that the student withdrew. An institution may use as the student's withdrawal date a student's last date of attendance at an academically related activity. Condition: There were instances when the College did not use the correct withdrawal date in the return of title IV funds (R2T4) process, and they could not provide some COVID-19 related documentation. Questioned Costs: None Context: During our testing, we noted 2 of the 12 students tested for R2T4 did not use the correct withdrawal date to determine the amount of title IV grant or loan assistance that was earned by the student. The student?s records of academically related activity did not agree with the dates used in the institutional R2T4 calculations. None of the errors resulted in an incorrect return of funds. Documentation that a withdrawal was COVID-19 related was missing for 2 of 12 students. Cause: There was no process to use the last date of academically related activity to determine the last date of attendance for the R2T4 calculation. Effect: The College was not in compliance with how the R2T4 calculation was prepared. Repeat Finding: No Recommendation: We recommend the process be put in place to ensure that the student's last date of attendance at an academically related activity is used in the R2T4 calculation, and we recommend the College retain all documentation related to the R2T4 calculation. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend the process be put in place to ensure that the student's last date of attendance at an academically related activity is used in the R2T4 calculation, and we recommend the College retain all documentation related to the R2T4 calculation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The CCC Financial Aid Office in its processing and review of student R2T4 calculation is working with the Registrar to ensure all R2T4?s performed use the official LDA. Upon review of the Anthology system, inconsistencies were noted in the dates used by the system for the official LDA. Official student records were and continue to be compared to the R2T4?s performed. Documentation of the R2T4, LDA used and the official student record will be maintained in the student record. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse, Director of Financial Aid Planned completion date for corrective action plan: The LDA review process is now being done and is ongoing

Criteria or specific requirement: Per the Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have observable controls to test over lost revenue calculations. Questioned Costs: None Context: During our testing of lost revenue calculations, we were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner. We did not find any noncompliance, but we did note that this process was not being reviewed to prevent, detect, or deter errors from occurring. Cause: A control system to prevent and detect errors during the lost revenue calculation did not occur or had not been created. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend someone other than the preparer of the lost revenue calculations review for accuracy. Views of responsible officials: There is no disagreement with the audit finding.

Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend someone other than the preparer of the lost revenue calculations review for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: If lost revenue were to be recorded, it would be prepared by the Director of Accounting and reviewed in writing by the President. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla, Director of Accounting Planned completion date for corrective action plan: Completed

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria: 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. 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. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment status of 8 of the 40 students tested was not reported correctly to NSLDS. The enrollment effective date of 5 of the 40 students tested was not reported correctly to NSLDS. The status change of 8 of the 40 students tested was not reported timely to NSLDS. The program begin date of 11 of the 40 students tested was not reported correctly to NSLDS. Questioned Costs: None Cause: Management did not determine if student status changes in enrollment and program were being updated accurately and timely and they did not ensure the error reports were timely responded to. Effect: The College was not in compliance with the requirements to timely respond to error reports and to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: Yes Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Education CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that the College put a process in place to ensure all error reports are updated within the required 10 days. They should also establish a process to ensure all students who have a status change are accurately and timely reported to NSLDS. This process should include understanding of NSC?s processes and ensuring they are correctly reporting to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar has identified additional staff to work on National Student Clearinghouse errors. These errors will be cleaned up in both CCC and NSC?s within the 10 day period with the error not occurring in the next submission. The Office of the Registrar will periodically review that NSC is submitting timely to NSLDS. The new institutional SIS system will be used to monitor student status. This will be done through reports, intermittently reviewing NSLDS and the use of student groups. A change in a student?s program version or withdrawal will be assessed using the new SIS system throughout the term and updated will be entered into NSLDS directly, if necessary. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum, Registrar Planned completion date for corrective action plan: July 1, 2021

2019-001

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria: 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 and Context: 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. During our audit procedures, it was noted that the College 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. We did note a risk assessment was performed in July 2020 that covered some of the required elements. Questioned Costs: None Cause: The organization did not perform an IT Risk Assessment in the current year. Effect: The College was not in compliance with the requirements of the Gramm-Leach-Bliley Act. Repeat Finding: Yes Recommendation: We recommend the College review the risk assessment performed in July 2020 and ensure it addresses all of the requirements in 16 CFR 314.4(b). Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the College review the risk assessment performed in July 2020 and ensure it addresses all of the requirements in 16 CFR 314.4(b). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy this situation, a Data Security workgroup has been formed which is identifying, classifying, and prioritizing data security weaknesses. The group will then develop plans for addressing these weaknesses and implement them across the college. Workgroup membership currently includes the following positions: Vice President Student Success, Vice President Finance and Operations, Director Information Technology, Director Financial Aid, Director Accounting Services, Registrar, Director Human Resources. The first meeting occurred on February 18, 2021. The group identified several vulnerabilities and is currently developing plans for addressing them. The group is also evaluating several comprehensive evaluation tools that have been adopted by other institutions. Name(s) of the contact person(s) responsible for corrective action: Jerad Sorber, Vice President for Student Success Planned completion date for corrective action plan: Ongoing over the current award year.

2019-003

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria: Federal regulation requires enrollment status for each student be reported accurately to NSLDS. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that do not pass the NSLDS enrollment reporting edits. Condition and Context: During our testing, we noted that the National Student Loan Data Systems (NSLDS) rosters returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third party provider in order to submit student information to NSLDS. In addition, we noted that the enrollment of 2 of the 40 students tested were not reported to NSLDS correctly. Questioned Costs: None Cause: Management did not determine if student status changes were being updated accurately and timely. Effect: The College did not update student enrollment statuses correctly or timely to NSLDS. Repeat Finding: No Recommendation: We recommend that the College put a process in place to ensure all students who withdraw or graduate are accurately and timely reported to NSLDS. The system should include understanding if and when the NSC third party servicer has correctly reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

2019-001 Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend that the College put a process in place to ensure all students who withdraw or graduate are accurately and timely reported to NSLDS. The system should include understanding if and when the NSC third party servicer has correctly reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Institutional procedures in regards to National Student Clearinghouse have been reviewed. NSC submission ?reminders? including Enrollment Transmission and Error Resolution emails will now be sent to the Office of Financial Aid in addition to the Registrar. To ensure that all students who graduate are accurately reported to NSLDS the Office of the Registrar will isolate all potential graduates through monitoring of accumulated relevant credits in addition to the existing student submitted ?Petition for Graduation?. This new process will allow timely monitoring of potential graduates allowing for accurate reporting to NSLDS. To ensure that all students who totally withdraw are reported accurately to NSLDS the Office of the Registrar will work with the institutional software provider and the institutional researcher to create and generate a reporting mechanism that will catch total withdrawals in a timely manner. This monitoring/reporting process will be conducted regularly to ensure all students who totally withdraw are reported to NSLDS within the defined time limits. Name(s) of the contact person(s) responsible for corrective action: Lloyd Mueller, Director of Financial Aid Planned completion date for corrective action plan: Corrective actions are being instituted at this time. Full implementation will be realized by March 20, 2020.

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition and Context: During our testing of the R2T4 process, we did not find any noncompliance. However, we were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner. We tested the refund calculations and noted the calculations were not being reviewed by someone other than the preparer. Questioned Costs: None Cause: A control system to prevent and detect errors during the refund process has not been created. Effect: It is possible for errors to occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend someone other than the preparer of the refund calculation review the report for accuracy. Views of responsible officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend someone other than the preparer of the refund calculation review the report for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop?s Financial Aid Office?s has instituted a procedure that requires that all R2T4?s will be reviewed by someone other than the preparer. An example would be: if the Director prepares the R2T4 the Assistant Director will review the calculation for accuracy. Documentation of the review will be kept with the original R2T4 calculation. The CCC Financial Aid Policy and Procedure Manual has been updated to include the new procedure. Name(s) of the contact person(s) responsible for corrective action: Lloyd Mueller, Director of Financial Aid Planned completion date for corrective action plan: The plan has been put in place.

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Criteria: 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 and Context: 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. 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. Questioned Costs: None 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.

Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster: CFDA Number: 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work Study Program 84.063 ? Federal Pell Grant Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 to June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matter Recommendation: We recommend the Organization perform a risk assessment which addresses all of the requirements in 16 CFR 314.4(b). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop will seek to identify through an institutional risk assessment reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information. Clatsop will also assess the sufficiency of safeguards in place to control these risks. The Clatsop risk assessment will include an evaluation of: Employee training and management, information systems, including network and software design, as well as information processing, storage, transmission and disposal; and detecting, preventing and responding to attacks, intrusions, or other systems failures. Clatsop will start planning and implementation of this plan immediately and conclude the process by June 30, 2020. Name(s) of the contact person(s) responsible for corrective action: Lloyd Mueller, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2020

GSA_MIGRATION

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2016-002

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2015-002