COLUMBIA GORGE COMMUNITY COLLEGE

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 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 accurately report the enrollment status of all students regardless of whether they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reporting 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: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Additionally, the College did not have a control process in place to ensure timely and accurate reporting. Questioned Costs: None. Context: In our sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 7 students had campus enrollment status reported incorrectly, 15 students had an enrollment effective date that did not match NSLDS, 60 students were reported past the 60-day reporting timeframe, 60 students were not certified every 60 days, 5 students where NSLDS Program enrollment effective date did not match the institutions records, 4 students where the students NSLDS Program enrollment status did not match the institutions records. Additionally, there was no observable review process to ensure timely and accurate reporting to NSLDS. Cause: The College did not have proper controls or procedures in place to verify student’s status in NSLDS matched the institution’s records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes. 2024-002. Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Views of responsible officials: There is no disagreement with the finding.

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the past year, the College (CGCC) has worked vigorously to bring NSLDS enrollment reporting up-to-date. The College currently reports enrollment data to NSLDS through the National Student Clearinghouse. The Registrar annually establishes the Clearinghouse reporting schedule based on CGCC’s quarter system, including term start, midterm, and end dates. The schedule is posted in the Clearinghouse system, and Clearinghouse sends email reminders before scheduled reporting dates. The Registrar completes the scheduled reporting process, reviews posting results and error reports when received, and resolves any identified errors promptly to allow the enrollment file to be processed and reported. Going forward, the internal control will be to add secondary review by providing the retained report to the Vice President of Student Services. The report will include the date reviewed/submitted and the Registrar’s initials, and the Vice President will also initial the report as evidence of review. This provides documentation of completion and accountability to help ensure enrollment reporting is completed in a timely fashion. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham. Planned completion date for corrective action plan: June 30, 2027.

2024-002

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance 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 appropriate 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. Unclaimed Title IV FSA funds must not escheat to the state, revert to the College, or be transferred to any other third party. Condition: The College does not have a control in place to specifically monitor outstanding Title IV federal funded checks issued to students. This absence of oversight prevents the College from ensuring that these funds are returned within 240 days of check issuance. Questioned Costs: N/A. Context: During our testing, it was noted the College did not have a control in place to ensure the return of outstanding Title IV federally funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. Cause: The College did not have a control in place to ensure outstanding Title IV checks over 240 days are sent back to the Department of Education. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over outstanding checks and refunds of disbursements to students. Repeat Finding: Yes, 2024-003. Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks. Views of responsible officials: There is no disagreement with the finding.

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

2024-003

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30 days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately calculate Return of Title IV (R2T4) calculations. The College also did not maintain documentation of the internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: $5,458. Context: During our testing, it was noted out of our sample of 15, 2 students R2T4 calculation was not performed or not mechanically performed correctly. Additionally, the College does not have a formal review process in place to ensure compliance with federal laws, regulations, and program compliance requirements. Cause: The College does not have proper procedures in place to ensure R2T4 calculations are performed accurately and did not maintain documentation of the controls in place to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: Failure to properly calculate R2T4 could result in the student returning an incorrect amount of aid. Further the lack of evidence of an internal control in place to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. We also recommend the College maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will ensure that all Financial Aid policies and procedures are up-to-date; reviewed annually; and revised, as needed. Documentation will also be made for any procedures that are currently being performed by their third-party-servicer, Global including Return to Title IV (R2T4) calculations. As an internal control, the Financial Aid Office will retain records of the Return to Title IV calculations performed by Global; sign-off on the appropriate reports with the date reviewed; include the initials of the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. The Coordinator of Financial Aid will notify Global of funds to be returned by the institution and/or student by completing the established process (GARP) to ensure that the funds are returned to the Department of Education within 45 days of the Date of Determination. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

2024-005

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Material Weakness in Internal Control Over Compliance; Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 682.604) states a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school, and that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program that the home institution approves for credit, written counseling materials may be provided by mail within 30 days after the student borrower completes the program. If a student borrower withdraws from school without the school's prior knowledge or fails to complete an exit counseling session as required, the school must, within 30 days after learning that the student borrower has withdrawn from school or failed to complete the exit counseling as required, ensure that exit counseling is provided through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Additionally, 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: The College did not send exit counseling notifications to students who graduated or withdrew during the fiscal year. Questioned Costs: None Context: During our eligibility testing, it was noted 6 of 6 students who were in our eligibility sample and either graduated or withdrew did not receive exit counseling notifications. Cause: The College did have a process within its system to send out exit counseling notifications, but it was not set up properly and students were not being notified of exit counseling requirements. The College did not have proper controls in place ensure exit counseling notifications were being sent out. Effect: The College is not in compliance with Department of Education requirements over exit counseling. Repeat Finding: No. Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdraw students throughout the year. Views of responsible officials: There is no disagreement with the finding.

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since August 2025, the College has taken steps in conjunction with its SIS Managed Services team (Anthology) to establish an automated process to notify graduate/withdrawn students to complete the Exit Counseling requirement. Since then the Director of Financial Aid has been spot-checking the notifications to ensure that the exit counseling notification is being triggered for withdrawn students. Going forward, the Financial Aid Office will use the Task Function in Anthology to confirm that the notification has been sent and close the task which will be timestamped with the name of the reviewer. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.268, 84.063, 84.007, 84.033 Federal Award Identification Number and Year: P268K257727, P063P247727, P007A249116, P033A249116 Award Period: July 1, 2024 - June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance; Compliance, Other Matter Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to 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 Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards must establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, regulations, and the terms and conditions of the award. Condition: The College did not properly identify students on satisfactory academic progress (SAP) suspension, resulting in disbursement of aid to ineligible students. Questioned Costs: $5,530 Context: During our testing of 60 students, we identified 4 students who were not meeting Satisfactory Academic Progress (SAP) requirements and were not placed on SAP suspension and received aid they were ineligible for. Cause: The college does not have a proper process to ensure students not meeting SAP requirements are not disbursed aid. Effect: Ineligible students received Title IV funds. Repeat Finding: 2024-006. Recommendation: We recommend that the College review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institutions SAP policy. Views of responsible officials: There is no disagreement with the finding.

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

2024-006

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must accurately report the enrollment status of all students regardless of whether they receive aid from the institution or not. This includes the enrollment effective date and related enrollment status, which must be reporting 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: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Additionally, the College did not have a control process in place to ensure timely and accurate reporting. Questioned Costs: None. Context: In our statistically valid sample of 60 students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified 22 students that had the campus enrollment status reported incorrectly, 24 students had incorrect enrollment effective date, 60 students were reported past the 60-day reporting timeframe, 60 students were not certified every 60 days, five students had no record listed in NSLDS, three students where NSLDS Program enrollment effective date did not match the institutions records, two students where the students NSLDS Program enrollment status did not match the institutions records, one student had incorrect program length, and one student had a program begin date that did not match institutional records. Additionally, there was no review process 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: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes. 2023-004. Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Views of responsible officials: There is no disagreement with the finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. The reporting of enrollment information in a timely manner for the year ended June 30, 2024, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2024, the Registrar continues to work on mitigating any issues that negatively impact enrollment reporting. Our reporting have significantly improved during the 2024-2025 academic year. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham Planned completion date for corrective action plan: 9/30/2025

2023-004

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 appropriate 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. Unclaimed Title IV FSA funds must not escheat to the state, revert to the College, or be transferred to any other third party. Any Title IV, HEA credit balance must be paid directly to the student or parent promptly, within 14 days of its occurrence, whether before or after the first day of class for a given payment period. Condition: The College does not have a control in place to specifically monitor outstanding Title IV federal funded checks issued to students. This absence of oversight prevents the College from ensuring that these funds are returned within 240 days of check issuance. Additionally, the College does not have a control in place to monitor that student refunds are disbursed within 14 days of its occurrence. Questioned Costs: None. Context: During our testing, it was noted the College did not have a control in place to ensure the return of outstanding Title IV federally funded checks that were old and needed to be returned to the U.S. Department of Education prior to 240 days after issuance. It was also noted that the College did not have a control in place to ensure student refunds are disbursed to students within 14 days of its occurrence. Cause: The College does not have a control in place to ensure federal refunds are sent to students within 14 days and that any uncashed federal checks over 240 days are sent back to the Department of Education. Effect: The College is not in compliance with Department of Education requirements to establish internal controls over outstanding checks and refunds of disbursements to students. Repeat Finding: No. Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the year. Views of responsible officials: There is no disagreement with the finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed its policies and procedures in relation to the audit finding and has implemented adjustments to its posting process to ensure more accurate recording of transaction dates that initiate the Title IV credit balance process. In addition, targeted training and coaching have been provided to responsible personnel to reinforce compliance and improve the timeliness of student refunds in accordance with statutory timeframes. Emphasis has been placed on the communication and coordination between the Financial Aid and Business office to ensure that batches are posted in a timely fashion in accordance with the disbursement dates on COD. Additionally, for instances of uncashed refund checks resulting from Title IV credit balances, the Business Office will collaborate with Financial Aid to ensure the return of funds to the appropriate federal programs within 240 days of the date of issuance. Name(s) of the contact person(s) responsible for corrective action: Sam Draper & Denise Reid-Strachan Planned completion date for corrective action plan: 6/30/2026

Criteria or specific requirement: 34 CFR 668.22(a)(1) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a period of enrollment that the recipient began attendance in, the institution must determine the amount of Title IV assistance that the student earned in accordance with 34 CFR 668.22(e) which states that the calculation to determine this is equal to the percentage of the period of enrollment that the student completed as of the withdrawal date if this date occurs before completion of 60% of the period of enrollment. The amount unearned by the student is the complement of this percentage and is required to be returned as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew as described in 34 CFR 668.22(j)(1). The withdrawal date is the date by which the student began the withdrawal process or provided official notification to the institution of intent to withdraw. If the student ceased attendance without providing notification to the institution the midpoint of the period of enrollment should be used. If the student’s ceasing attendance is due to illness, accident, or other circumstance beyond the students control the withdrawal date is date the institution becomes aware of these circumstances, as described in 668.22(c). Further (j)(2) states an institution not required to take attendance must determine the withdraw date for students who withdraw without providing notification to the institution no later than 30. Criteria or specific requirement (continued): days after the end of the earlier of the period of enrollment, academic year in which withdrawal occurred, or education program for which the student withdrew. Additionally, per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain effective internal controls designed to reasonably ensure compliance with federal laws, regulations, and program requirements related to these awards. Condition: The College did not accurately determine student withdrawal dates, leading to incorrect Return of Title IV (R2T4) calculations. Additionally, withdrawals were not identified in a timely manner, and funds were not returned within the required 45-day period. The College also lacked internal controls to ensure the R2T4 process complied with federal regulations and guidelines. Questioned Costs: None. Context: During our testing, we identified exceptions in 7 out of 16 sampled student records. Specifically: • 5 students had incorrect withdrawal dates recorded. • 2 students had Return of Title IV (R2T4) calculations that were not accurately performed. • 3 students experienced delays in withdrawal determination beyond 30 days of their enrollment period, and for these same students, funds were not returned to COD within the required 45-day timeframe. Furthermore, the College lacks a formal review process to ensure adherence to federal laws, regulations, and program compliance requirements. Cause: The College did not establish precise controls to ensure compliance with federal laws, regulation and program compliance requirements over R2T4. Effect: The lack of an internal control to ensure compliance with federal requirements could result in errors going undetected by the College. Repeat Finding: Yes, 2023-005, 2023-008. Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC is currently undertaking a comprehensive review of its Return to Title IV (R2T4) process. In light of recent staff departures, we are reassessing the applicable regulations and developing a formalized workflow, including clear documentation of our internal controls to support consistent and compliant implementation. Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

2023-005, 2023-008

Criteria or specific requirement: The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to 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 Title IV, HEA programs. Per 2 CFR 200.303, nonfederal entities receiving federal awards must establish and maintain effective internal control designed to reasonably ensure compliance with federal laws, regulations, and the terms and conditions of the award. Condition: The College did not properly identify students on Satisfactory Academic Progress (SAP) suspension, resulting in disbursement of aid to ineligible students. Questioned Costs: $21,381 Context: During our testing of 60 students, we noted 8 students who did not meet SAP requirements and were not placed on SAP suspension. Cause: The students' SAP statuses were not being calculated within the College’s system due to a known system issue and notifications of a change in SAP standing were not sent out to students. Effect: Ineligible students received Title IV funds. Repeat Finding: 2023-008. Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administrator to resolve the SAP calculation issue or implement an alternative method for tracking SAP compliance. Views of responsible officials: There is no disagreement with the finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administrator to resolve the SAP calculation issue or implement an alternative method for tracking SAP compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has completed a thorough review of its Satisfactory Academic Progress (SAP) policy to ensure alignment with the capabilities and limitations of our current system. We remain committed to resolving ongoing system-related issues and are actively keeping the policy and system functionality in sync as improvements are made. The issue regarding SAP not calculating correctly is still in progress. We have been working closely with Anthology to identify and implement long-term solutions. Unfortunately, the necessary fixes require significant time and manual intervention. Despite these challenges, we have made progress: as of Spring 2025, we are now able to accurately identify affected students—something that was not possible during the 2023–2024 award year. Additionally, we are in the process of hiring a Financial Aid Director. This added leadership and support will help us address the remaining issues more efficiently and continue making meaningful progress toward full resolution Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

2023-008

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 676.10(a)(1) and (2) states “In selecting among eligible students for FSEOG awards in each award year, an institution shall select those students with the lowest expected family contributions who will also receive Federal Pell Grants in that year. If the institution has FSEOG funds remaining after giving FSEOG awards to all such students who will receive Pell Grants, the institution may award the remaining funds to other eligible students.” Furthermore, institutions are required to ensure that only eligible recipients receive Federal Pell Grants. 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, statutes, regulations and terms and conditions of the federal award. Condition: The College awarded FSEOG funds to students with Expected Family Contributions (EFCs) above zero, while eligible students with zero EFCs were not awarded. Questioned Costs: None. Context: Out of 8 FSEOG recipients tested, one FSEOG recipient had an EFC greater than zero while eligible students with zero EFCs were not awarded FSEOG. Cause: A reporting error in the financial aid system misclassified a student’s EFC, leading to incorrect award decisions. Effect: The College did not comply with FSEOG awarding guidelines, which prioritize students with the lowest EFCs. Repeat Finding: No. Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Views of responsible officials: There is no disagreement with the finding.

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has reviewed its Federal Supplemental Educational Opportunity Grant (FSEOG) awarding policy and will continue to ensure that FSEOG funds are awarded in accordance with federal guidelines. The discrepancy between the 2023–2024 award year and the current year was due to inaccurate Student Aid Index (SAI) data generated by a previous report. For the current year, the Financial Aid Office has identified and implemented a more accurate reporting tool, which has significantly improved the reliability of the SAI data used in awarding decisions. To further strengthen our internal controls and oversight, a new Financial Aid Director will be joining our team in June 2025. This leadership addition will enhance our ability to maintain compliance and ensure accurate, consistent awarding of FSEOG funds moving forward.. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister Planned completion date for corrective action plan: 6/30/2025

Criteria or specific requirement: In accordance with 29 CFR section 5.5, Davis-Bacon Act (currently known as Wage Rate Requirements) requires that all contractors and subcontractors performing on federal contracts (and contractors or subcontractors performing on federally assisted contracts under the related Acts) in excess of $2,000 pay their laborers and mechanics not less than the prevailing wage rates and fringe benefits listed in the contract’s Davis-Bacon wage determination for corresponding classes of laborers and mechanics employed on similar projects in the area. Each covered contractor and subcontractor must, on a weekly basis, provide the entity with a copy of all payrolls providing the information listed under 29 CFR 5.5(a)(3)(ii)(B) for the preceding weekly payroll period. The contractor, subcontractor or authorized officer or employee of the contractor or subcontractor who supervises the payment of wages must sign the weekly payroll and certification statement. Further 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 receive or review the required weekly certified payrolls from subcontractors and contractors. Questioned Costs: None. Context: During our testing of two contracts with contractors/subcontractors that were subject to the Davis-Bacon wage rate requirements the College did not obtain the certified payrolls from the contactors/subcontractors and document their review and approval of them. Cause: The College was not aware of the requirement to obtain and review weekly certified payrolls prior to processing the vendor payment. Effect: The College was not in compliance with the Department of Commerce’s wage rate requirements under special tests and provisions. Repeat Finding: No. Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Views of responsible officials: There is no disagreement with the finding.

Economic Development Cluster – Assistance Listing No. 11.307 Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process workflow has been developed to ensure that the certified payroll reports are requested and reviewed monthly prior to paying the monthly invoices or pay applications to the contractor. Name(s) of the contact person(s) responsible for corrective action: Saundra Buchanan and Sam Draper Planned completion date for corrective action plan: 7/28/2025

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 18 disbursements to students out of a population of 113 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the College did not have a documented plan that clearly outlined the plan for disbursement. Additionally, we were unable to obtain clear documentation of the rationale for approval of award amounts for students selected. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The College did not have the controls in place to formerly approve a plan for distribution of funds that was documented and circulated to the College. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – No Recommendation – We recommend the College adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds were to be distributed to students. Views of responsible officials and planned corrective actions – Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Michael N. Espinoza, Vice President of Student ServicesCorrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the audit process. Three independent outreach efforts were implemented to contact, support, and release funding to students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect execution. Documentation was provided for all sample disbursements with a few instances of missing documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF funding was distributed to students that met eligibility requirements within the June 30, 2023, disbursement deadline. Ongoing efforts include the following:  The college will continue to archive and document all disbursement records.  Continued implementation of processes and procedures for all aid disbursement to prevent future instances. Anticipated Completion Date: Completed June 30, 2023

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Federal Agency Name: Department of Education Federal Assistance Listing Number: 84.425E Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion Finding Summary: The College did not have consistent controls in place to formerly approve a plan for distribution of funds that was documented and circulated to the College. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Responsible Individuals: Dr. Lorelle Davies, Chief Financial Officer Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: HEERF procedures and processes were adopted and provided to the auditors during the audit process. Three independent outreach efforts were implemented to contact, support, and release funding to students. Limited staffing and a sense of urgency in emergency disbursements contribute less than perfect execution. Documentation was provided for all sample disbursements with a few instances of missing documentation. The Rubric for disbursement through Student Services based on a Pell and enrollment need evaluation was not available to auditors. The college can reproduce criteria to support disbursement. All HEERF funding was distributed to students that met eligibility requirements withing the June 30, 2023, disbursement deadline. Ongoing efforts include the following:  The college will continue to archive and document all disbursement records.  Continued implementation of processes and procedures for all aid disbursement to prevent future instances. Anticipated Completion Date: Completed June 30, 2023

2023-004 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – The College did not report enrollment status changes to NSLDS during the 2022-2023 award year. Questioned costs – None reported. Cause/effect – The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. 94 Repeat finding – Yes, 2022-003 Recommendation – The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under these programs to ensure their status and all relevant student data is correct on NSLDS. Views of responsible officials and planned corrective actions – Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting.  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Finding Summary: The College did not have controls in place to ensure the reporting of enrollment information under the Pell grant and Direct loan programs via NSLDS was completed. Due to the way the College’s software pulls the roster information, the Clearing House is unable to send the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the prior award year and has not resumed. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Repeat finding – Yes, 2022-003 Responsible Individuals: Mary Martin, Registrar Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2023, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2023, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by:  working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner.  working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting. 106  working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes.  consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported.  prompt resolution of reporting errors.  identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: to be completed by June 30, 2024

2022-003

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007 95 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – The College is not properly identifying students who have withdrawn from the institution for whom a R2T4 calculation is necessary. The College was unable to provide a complete population of official and unofficial withdrawals with accurate withdrawal dates for testing. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, we were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Repeat finding – No Recommendation – We recommend the College review their policies, procedures and controls to ensure students who have withdrawn from the institution are being identified, and that R2T4 calculations are performed and maintained for those students. We also recommend the College ensure all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-005 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster Department of Education Finding Summary: This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates, and a lack of understanding of compliance requirements. This resulted in a failure to properly identify students requiring calculation for return of funds to the federal government, or eligibility for post withdrawal disbursement. As a result, the auditors were unable to determine if the College is remitting unearned funds to the federal government, or offering eligible students post withdrawal disbursements if available to them. Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Corrective Action Plan: The college entered into a third-party contract to manage financial aid packaging and awarding. Integration and processes for the R2T4 calculation with the third-party processer was not completed correctly. New integrations, policies, and processes to be adopted in fiscal year 2023-24.  Develop and implement ongoing tracking and reporting for all financial aid reporting.  Financial Aid and Student Accounts work to regularly review and action student account files.  Continue to work with third-party service to review and promptly return Title IV funding in compliance with federal rulings. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 96 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: Per 16 CFR 314.3, institutions subject to the requirement shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to the size and complexity, the nature and scope of their activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in 16 CFR 314.4 and shall be reasonably designed to achieve the objectives of 16 CFR 314.3(b). These requirements were effective as of June 9, 2023. Condition/context: Based on our review of the information provided by the College, they do not currently have a written policy that addresses the required elements in 16 CFR 314.4. Questioned costs: None. Cause/Effect: Staffing shortages have contributed to the delay in implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Repeat finding: No Recommendation: We recommend the College review the compliance requirements and draft a written policy that addresses all the required elements under the act. Views of responsible officials and planned corrective actions: Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-006 – Gramm-Leach-Bliley Act – Student Information Security – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program 107 Finding Summary: Staffing shortages have contributed to the delay in the implementation of this standard. The absence of a well-designed and documented policy addressing the standards set forth under the act could put the security, confidentiality, and integrity of student information at risk. Responsible Individuals: Andrew Burke, Chief Information Officer Corrective actions Plan: The college released a Request for Proposal (RFP) to contract with outside information technology services to guide the development and implement a comprehensive information security program and address staffing gaps. Outside Chief Information Officer, information security, and technical partnership completed and contracted effective April 2024. Outside service will guide the college in the review and implementation of procedures and policies necessary for the required controls to be completed through the following phase:  Assessment and gap analysis of current infrastructure and cybersecurity measures.  Develop necessary policies and procedures based on NIST guidelines and GLBA requirements.  Detect and respond to ongoing training and incident response planning. Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Criteria: The cost of attendance (COA) is the cornerstone of establishing a student’s financial need, as it sets a limit on the total aid that a student may receive for purposes of the Campus-Based, TEACH Grant, and Direct Loan programs, and is one of the basic components of the Pell Grant calculation. COA is determined by law (Higher Education Act, Sec. 472) and is not subject to regulation by the Department of Education. The law specifies the types of costs that are included in the COA, but each school must determine the appropriate and reasonable amounts to include for each eligible COA category for its students, based on the criteria described in the Federal Student Aid Handbook. Condition/context: During our testing of 30 students out of a population of 292 students who received federal awards during the year, the College was unable to provide a schedule that included the complete budgeted cost of attendance used for packaging the 2022 – 2023 award year. As a result, we were not able to conclude that the cost of attendance used in packaging each student or the award amounts disbursed were appropriate. We could not conclude that the total aid awarded did not exceed the student’s financial need or cost of attendance. In addition, we noted the following issues while testing eligibility. Out of a population of 30 students: - Using the cost of attendance noted on the award letter, we were unable to recalculate the Pell award disbursed for 6 students. - We noted during review of satisfactory academic progress, 4 students appeared to be receiving awards in period of suspension. We were unable to obtain evidence that the students had applied and been approved for an appeal or other rationale for continued receipt of Title IV funds. - For 2 students who withdrew from the institution, Title IV funds received do not appear to have been evaluated for return to Title IV. - For 2 students, refunds of credit balances created by disbursement of Title IV funds were not issued to students within the required timeframe. - For 1 student, based on the cost of attendance per the award letter, the student appeared to be over awarded - For 1 student, Title IV funds disbursed were not properly reflected on the student ledger. - For 1 student, the award letter did not reflect an award during a term for which a student received a Title IV disbursement. - For 1 student, Title IV aid was disbursed multiple periods after the award was made. Questioned costs: Undeterminable. Cause/Effect: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. We are not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No 99 Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Views of responsible officials and planned corrective actions: Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Recommendation: We recommend the College review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College should review all processes and procedures related to eligibility to ensure controls are well documented and allow them to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2023-008 – Eligibility – Material Weakness in Internal Controls over Compliance and Material Noncompliance Student Financial Assistance Cluster U.S Department of Education Federal Assistance Listing Number: 84.063, 84.268, 84.007, 84.033, 84.379 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans, Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program Finding Summary: The College did not have adequate controls in place to ensure the appropriate and reasonable amounts were included in each eligible cost of attendance category for its students, that awards were properly calculated, refunds were disbursed timely and student records were accurate. The auditors were not able to conclude that the College is in compliance with eligibility requirements in the OMB compliance supplement. Repeat finding: No Responsible Individuals: Michael N. Espinoza, Vice President of Student Services Views of responsible officials and planned corrective actions: The college entered into a third-party contract to manage financial aid packaging and awarding. Calculation and reporting completed by prior Financial Director submitted national average as the college calculations instead of college service area specific calculations. The college worked with the third-party provider to ensure policies and processes adopted in July 2023 to ensure cost of attendance (COA) reporting and calculations are complete and accurate going forward. Corrective Action: The College will review their policies, procedures and controls to ensure that annually a cost of attendance schedule is approved, and that the approved schedule is used in packaging student financial aid. Rationale for adjustments made to the budgeted cost of attendance for individual students should be documented and support maintained. The College will review all processes and procedures related to eligibility to ensure controls are well documented and to properly adhere to requirements for eligibility of Title IV aid. Anticipated Completion Date: to be completed by June 30, 2024

2022-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P217727, P268K227727, P007A219116, P033A219116 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Material Noncompliance and Material Weakness in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Further, we noted that students who were not enrolled at the College have no relevant program information or students who previously withdrew from classes in earlier years have outdated CIP information. Students who were previously enrolled and withdrew prior to implementation of the new software show as ?Withdrawn? and students who were not previously enrolled have no information and show as ?N/A?. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. Due to the way the College?s new software pulls the roster information to send to the Clearing House, the Clearing House is unable to push the data to NSLDS. While the College has been working with the software vendor to correct this issue, the reporting process for NSLDS stopped in the current year. Management did not implement other processes or procedures to deal with the issues encountered with the software to fulfill their responsibility to ensure accurate and timely reporting and submission of student status during the year. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. The issue is pervasive and uncorrected and is considered a material noncompliance and a material breakdown in the controls over compliance. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 244 students in the 2021- 2022 school year. A non-statistical sampling of 60 students with 151 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 and 2021-003 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website, regardless of whether or not it has to be done manually in situations where the software is not reporting correctly. Management should immediately go through all students that were awarded funds under this program to ensure their status and all relevant student data is correct on NSLDS. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.

Finding 2022-003 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN 84.007, 84.033, 84.063, 84.268 Finding Summary: During our testing over the NSLDS reporting requirements, we noted that 27 enrollment status certifications out of 151 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 57 enrollment statuses out of 151 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Responsible Individuals: Mary Martin, Registrar Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2022, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student record procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2022, the Registrar continues working to mitigate any issues negatively impacting enrollment reporting by: ? working with the Vice President of Student Services and Director of Financial Aid to establish internal checks and balances to ensure reporting is being done in a timely manner; ? working with SIS system support staff and internal IT staff to promptly address technical issues and/or other issues impacting enrollment reporting; ? working with National Student Clearinghouse representative to ensure reporting schedule meets required timeframes; ? consistent review of enrollment files prior to submission to ensure correct student enrollment statuses and program information are being reported; ? prompt resolution of reporting errors; ? identifying and training of additional staff on enrollment reporting. Anticipated Completion Date: Ongoing

2021-003

2021-003 Federal Agency: U.S. Department of Education Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Award Number: P063P207727, P268K217727, P007A209116, P033A209116 2020-21 Program Name: Student Financial Assistance Cluster Special Tests and Provisions ? Enrollment Reporting Significant Deficiency in Internal Control over Compliance Criteria - OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: ?Campus Level? and ?Program Level?, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition - During our testing over the NSLDS reporting requirements, we noted that 9 enrollment status certifications out of 285 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 3 enrollment statuses out of 285 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Cause - The College did not have adequate and/or functioning controls in place to ensure the reporting of enrollment information under the Pell grant and Direct and FFEL loan programs via NSLDS was timely. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Effect - The College is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement and required by the Department of Education. Questioned Costs ? None reported Context/Sampling - The College disbursed financial aid to approximately 360 students in the 2020-2021 school year. A non-statistical sampling of 60 students with 285 individual statuses collectively were selected for testing. Repeat Finding - Yes, prior year finding 2020-002 Recommendation - The College should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of Responsible Officials - Management agrees with this finding and will implement the recommendations.

Finding 2021-003 Federal Agency Name: Department of Education Program Name: Student Financial Assistance Cluster ALN #: 84.007, 84.033, 84.063, and 84.268 Finding Summary: During our testing over the NSLDS reporting requirements, we noted that 9 enrollment status certifications out of 285 enrollment certifications tested were not reported to NSLDS in the required timeframe. In addition, it was noted that 3 enrollment statuses out of 285 enrollment statuses tested did not agree to the enrollment status that was submitted to NSLDS. Responsible Individuals: Mary Martin, Registrar Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2021, was impacted by staff changes in the Registrar position which occurred in October 2019 and March 2020. In addition, when the current Registrar entered the position in April 2020 they did not receive enrollment reporting training (National Student Clearinghouse or NSLDS) from their predecessor. As a result of the Enrollment Reporting Finding for the year ended June 30, 2020, and as required by CGCC?s change to a new Student Information System, the Registrar is developing new internal Enrollment Reporting processes in conjunction with the CGCC Financial Aid Director and VP of Student Services. The new processes will ensure the following. Prevention of previous reporting issues by: ? establishment of standard monthly reporting schedule with National Student Clearinghouse; ? use of internal checks and balances to ensure reporting is being done in a timely manner; and ? utilization of National Student Clearinghouse training and support. Verify accurate reporting by:? detailed review of enrollment files prior to submission to ensure correct student enrollment statuses and program information details are being reported; and ? prompt resolution of SSCR reporting errors. Ensure continued compliance by:? maintaining open communication between Registrar and Financial Aid Office; ? keeping enrollment reporting policies and processes up-to-date; and ? identification and training of additional staff person as back-up for enrollment reporting. Anticipated Completion Date: Ongoing

2020-002

Finding Summary: During testing over the NSLDS reporting requirements, it was noted that 14 of 25 student enrollment changes tested were not reported to NSLDS in the required timeframe. Responsible Individuals: Mary Martin, Registrar

Corrective Action Plan: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. Reporting of enrollment information in a timely manner for the year ended June 30, 2020, was impacted by staff changes in the Registrar position which occurred in October 2019 and March 2020. In addition, when the current Registrar entered the position in April 2020 they did not receive enrollment reporting training (National Student Clearinghouse or NSLDS) from their predecessor. As a result of the Enrollment Reporting Finding for the year ended June 30, 2020, and as required by CGCC?s change to a new Student Information System, the Registrar is developing new internal Enrollment Reporting processes in conjunction with the CGCC Financial Aid Director and VP of Student Services. The new processes will ensure the following. Prevention of previous reporting issues by: ? establishment of standard monthly reporting schedule with National Student Clearinghouse; ? use of internal checks and balances to ensure reporting is being done in a timely manner; and ? utilization of National Student Clearinghouse training and support. Verify accurate reporting by: ? detailed review of enrollment files prior to submission to ensure correct student enrollment statuses and program information details are being reported; and ? prompt resolution of SSCR reporting errors. Ensure continued compliance by: ? maintaining open communication between Registrar and Financial Aid Office; ? keeping enrollment reporting policies and processes up-to-date; and ? identification and training of additional staff person as back-up for enrollment reporting. Anticipated Completion Date: Ongoing

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2015-002

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