Southwestern Oregon Community CollegeHigher Education

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 status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. 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 sixty student's selected for National student's Loan Data System (NSLDS) enrollment reporting testing, we identified one student's enrollment status did not match the enrollment status reported in NSLDS, twelve student's enrollment effective dates did not match those reported in NSLDS, fifteen student's enrollments were not reported to NSLDS in a timely manner, seven student's program enrollment effective dates did not match institutional records and, three student's program enrollment statuses that did not match institutional records. Additionally, 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 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, 2024-003. Recommendation: We 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.

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 status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. 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 sixty student's selected for National student's Loan Data System (NSLDS) enrollment reporting testing, we identified one student's enrollment status did not match the enrollment status reported in NSLDS, twelve student's enrollment effective dates did not match those reported in NSLDS, fifteen student's enrollments were not reported to NSLDS in a timely manner, seven student's program enrollment effective dates did not match institutional records and, three student's program enrollment statuses that did not match institutional records. Additionally, 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 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, 2024-003. Recommendation: We 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.

Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None. Context: We did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not maintain documentation of a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None. Context: We did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not maintain documentation of a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.

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 status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. 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 sixty student's selected for National student's Loan Data System (NSLDS) enrollment reporting testing, we identified one student's enrollment status did not match the enrollment status reported in NSLDS, twelve student's enrollment effective dates did not match those reported in NSLDS, fifteen student's enrollments were not reported to NSLDS in a timely manner, seven student's program enrollment effective dates did not match institutional records and, three student's program enrollment statuses that did not match institutional records. Additionally, 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 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, 2024-003. Recommendation: We 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.

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 status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. 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 sixty student's selected for National student's Loan Data System (NSLDS) enrollment reporting testing, we identified one student's enrollment status did not match the enrollment status reported in NSLDS, twelve student's enrollment effective dates did not match those reported in NSLDS, fifteen student's enrollments were not reported to NSLDS in a timely manner, seven student's program enrollment effective dates did not match institutional records and, three student's program enrollment statuses that did not match institutional records. Additionally, 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 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, 2024-003. Recommendation: We 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.

Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None. Context: We did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not maintain documentation of a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None. Context: We did not note evidence of a key control occurring for COD disbursement reporting. Cause: The College did not maintain documentation of a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: Yes, 2024-005. Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Code of Federal Regulations,2 CFR 200.332(c) states that the pass through entity must "evaluate each subrecipients fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring." The CFR then states in paragraph (e) that the entity must also "monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and terms and conditions of the subaward. In addition, the 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 have proper monitoring procedures in place to evaluate subrecipients fraud risk and risk of noncompliance and also did not have proper procedures in place to monitor that the subrecipient complied with federal statutes, and regulations. Questioned costs: None Context: During our testing of the one subrecipient in this program. We noted the College did not have policies and procedures to monitor subrecipients fraud risk, risk of noncompliance, and compliance with federal statutes and regulations. There was also no control in place to ensure compliance with subrecipient monitoring requirements. Cause: The College did not have proper monitoring procedures or controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Subrecipients could be noncompliant with federal statutes and the College would be unaware. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures along with an observable control to ensure that subrecipient monitoring requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

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. 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 of forty students, we noted two students that were under awarded in Subsidized loans. Questioned costs: None Context: During our eligibility testing of forty students, we identified two students who were under awarded in Subsidized loans. Cause: For one of the students the College's system applied the scholarship to the students account and incorrectly reduced the students subsidized loan award. For another student the student was packaged incorrectly and had unmet need and should have received a subsidized loan to meet unmet need before being awarded unsubsidized loans. Effect: Students were not awarded all the aid they were eligible for. Repeat Finding: No Recommendation: We recommend that the College review its process for packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly. Views of responsible officials: There is no disagreement with the audit finding.

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 status changes were not always reported timely, the program enrollment effective date did not match institutions records, and the program enrollment status did not match institutions records. 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 forty students selected for National Student Loan Data System (NSLDS) enrollment reporting testing, we identified one student where the enrollment was not reported timely to NSLDS, eight students where the program enrollment effective date did not match institutions records and three students where the program enrollment status did not match the institutions records. 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: No Recommendation: We 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 reporting. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: The College did not have observable controls to test for the R2T4 process. Questioned costs: None Context: During the testing of R2T4, we tested 23 students. We were unable to test a specific control in place to ensure that any error in the R2T4 process would be prevented and detected in a timely manner as there is only one person involved in the process from start to finish. Cause: There are no procedures to review R2T4 calculations by someone other than the person performing the calculation. Effect: It is possible that errors could occur and not be caught in a timely manner. Repeat Finding: No Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. 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 of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Questioned costs: None Context: During our testing of COD reporting, we were not able to test a control that ensures timely and accurate reporting to COD. Cause: The College did not have a control in place to ensure timely and accurate reporting to COD. Effect: A lack of timely reporting may prevent the university and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Views of responsible officials: There is no disagreement with the audit finding.

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)). ED provides additional information about cybersecurity requirements at https://studentprivacy.ed.gov/security. ED also issued an Electronic Announcement on GLBA compliance that can be found at https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-02-09/updates-gramm-leach-bliley-act-cybersecurity-requirements Condition: We identified that the College fails to meet some of the compliance requirements outlined in the GLBA Safeguards Rule. Questioned costs: None Context: During our testing, we noted the College did not meet one of the required elements outlined in the GLBA safeguards rule. Cause: The College did not have procedures in place to meet the requirements outlined in the GLBA safeguards rule. Effect: The College is not in compliance with the GLBA safeguards rule. Repeat Finding: No Recommendation: We recommend the College implement policies and procedures that meet all requirements outlined in the GLBA safeguards rule. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a non-federal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing of the procurement process, we noted that college was not in compliance with the federal procurement regulations. Questioned costs: None Context: In our sample of three procurement transactions, one transaction did not have the required procurement documentation. Cause: The College had an existing contract with a vendor and thought the transaction was covered under the original procurement. Effect: The College is not in compliance with procurement requirements to properly document the procurement rationale for the method of procurement. Repeat Finding: No Recommendation: We recommend the College revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Under section 2003(5) of the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2) (supplemental award or grant) by the U.S. Department of Education, Recipient must use a portion of their institutional funds received under this supplemental award to (a) to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965, as amended (HEA) (20 USC § 1087tt). In addition, Uniform Grant Guidance (2 CFR 20.303) requires nonfederal entities receiving Federal awards establish and maintain controls designed to reasonable ensure compliance with Federal laws, regulations, and program compliance requirements. Condition: During our testing, we noted there was no amount allocated to the earmarking requirement. Questioned costs: None Context: During our testing, we noted the College was not in compliance with the annual reporting requirements because the College did not report ARP funds expended to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances, described in section 479A of the HEA. Cause: The policies and procedures of the College did not ensure that annual reporting requirements to report amounts spent for earmarking requirements were accurately met. Effect: The College inaccurately reported the amount spent under earmarking requirements. Non-compliance with federal regulations could lead to funds being required to be returned or refunded in order to meet the reporting requirement. Repeat Finding: No Recommendation: We recommend the College revise their report to properly show the amount spent under earmarking requirements. In addition, we recommend the College put procedures in place to review earmarking requirements and properly track them for reporting purposes. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: 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. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. In addition, an annual report is required. Condition: The College did not report the correct amount for total quarterly expenditures for one of the quarterly reports tested. Questioned costs: None Context: One of two HEERF quarterly reports tested included data that did not agree to supporting documentation. Cause: The control system put in place for review of these reports is not operating effectively. Effect: The College reported an incorrect amount for total quarterly expenditures. Repeat Finding: No Recommendation: CLA recommends SOCC reviews its review process for these reports and implements a reconciling process between the report and the supporting documentation to make sure these things match before being signed off as reviewed. CLA also recommends a second reviewer of these reports. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. In addition, a suspension and debarment policy is required to be in place. Condition: During testing of one vendor paid over $25,000, it was noted there was no documentation to ensure one vendor was not suspended or debarred at the time of purchase. Due to no documentation of the vendor, there was also no review of the vendor. In addition, it was noted the College does not have an approved suspension and debarment policy. Questioned costs: None Context: During our testing, CLA noted one vendor was not checked to ensure they are not suspended or debarred at the time of purchase. In addition, due to not verifying the vendor, there is no review of the vendor. Lastly, it was noted the College does not have an approved suspension and debarment policy. Cause: The control system to prevent payment to a suspended and barred vendor was not in place. Effect: The College could have paid a vendor who is suspended or barred at the time of purchase. Repeat Finding: No Recommendation: CLA recommends for every vendor being paid with federal funds a cumulative amount of $25,000 for the fiscal year to be verified and documented the vendor is not suspended or barred. In addition, CLA recommends the College to implement a suspension and debarment policy. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student's enrollment status, the effective date of the status, and an anticipated completion date. 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. Condition: Student program level enrollment effective date does not match the campus level enrollment effective date. Context: During our testing of 40 students, CLA noted four student's program enrollment effective date per NSLDS's Program Level screen does not match the enrollment effective date on the Campus Level screen. Questioned costs: None reported. Cause: Student program level enrollment effective date does not match the campus level enrollment effective date. Effect: The College does not comply with Department of Education (ED) regulations relating to the reporting of student enrollment data to NSLDS. Repeat Finding: Yes, 2020-001 Recommendation: CLA recommends the College implement a procedure to insure the Program Level and Campus Level NSLDS screens reflect the same data. View of Responsible Official: The College agrees with the finding.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.203(a), outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. When awarding direct loans, schools should follow the guidelines for determining loan amounts for direct subsidized loans and offer the maximized amount. Condition: One student, out of 16 students tested who were awarded direct loans, was correctly awarded total direct loans of $5,500; however, the allocation between subsidized and unsubsidized loans was not correct. The amount for the subsidized loan was $2,326, and it should have been $3,500. The amount of unsubsidized loan was $3,174, and it should have been $2,000. Context: The student had received additional aid, and a new staff thought there was a need to re-allocate funds between the subsidized and unsubsidized loans. Questioned costs: None reported. Cause: The staff involved with making the changes was new and still learning the requirements. Effect: The student received the incorrect allocation of direct loans between subsidized and unsubsidized. Repeat Finding: No. Recommendation: CLA recommends the College continues to provide proper training, oversight and review of newer individuals involved with award packaging. View of Responsible Official: The College agrees with the finding.

Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: During testing of two vendors paid over $25,000, there was no documentation to ensure one vendor was not suspended or debarred at the time of purchase. Upon inquiry, we noted the College does not have a suspension and debarment policy or process. Context: During our testing, CLA noted one vendor was not checked to ensure they are not suspended or debarred at the time of purchase. Questioned costs: None reported. Cause: The control system to prevent payment to a suspended and barred vendor was not in place. Effect: The College could have paid a vendor who is suspended or barred at the time of purchase. Repeat Finding: No Recommendation: For every vendor being paid with federal funds a cumulative amount of $25,000 for the fiscal year, CLA recommends the College perform and document a verification process that the vendor is not suspended or debarred. In addition, CLA recommends the College to implement a suspension and debarment policy. View of Responsible Official: The College agrees with the finding.

Criteria or specific requirement: The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Reports are then required every 45 days after the initial 30-day report. On August 31, 2020, the Federal Registrar changed reporting from every 45 days to each calendar quarter. Each quarterly report is due 10 days after the end of the quarter. Condition: During our testing of the reporting process, we noted that there were no quarterly reports for the quarter ending March 31, 2021. Context: The College did not report on March 31, 2021 as all CARES funds were distributed prior to January 1, 2021. In addition, their CRRSAA funds were not distributed until April 2021, but the awards were awarded in January 2021. The March 31, 2021 report should have been issued and stated there were no funds disbursed. Questioned costs: None reported. Cause: The College did not have any student expenditures during this timeframe; therefore, they believed a report did not need to be updated. Effect: The College was not in compliance with HEERF reporting requirements. Repeat Finding: No Recommendation: CLA recommends the College establish a system to track due dates of reports to ensure timely submission. View of Responsible Official: The College agrees with the finding.

Federal Agency: Department of Education Federal Program Title: Student Financial Assistance 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: - Compliance, Other Matter - Significant Deficiency in Internal Control over Compliance 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. When a student withdraws during a term (or, in a nonterm program, during a payment period), the effective date for the withdrawn (`W?) status is the withdrawal date used by the institution in accordance with 34 CFR 668.22(c). In the case of the student who completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the `W? status is the final day of the term in which the student was last enrolled. The description within the National Student Loan Data System (NSLDS) Enrollment Reporting Guide (and compliance supplement) defines the Effective Date as: the date that the current enrollment status reported for a student was first effective. The important piece about the effective date is it starts the grace period for loans, so if a student is an unofficial withdrawal and the school uses 50% of the term for the return of Title IV (R2T4) calculation, then that date should be the effective date within NSLDS as well. In addition, institutions are required to certify enrollment every 60 days to ensure each students status is reported every 60 days. Condition and Context: In our statistically valid sample of forty (40) students selected for NSLDS enrollment reporting testing, we had the following exceptions: - 7 instances where the enrollment effective date per NSLDS did not match the program enrollment date - 17 instances where the begin date per the program enrollment detail did not match the institution's records - 1 instance in which the student was not certified every 60 days. - 1 instance where the student?s enrollment status was not properly updated Questioned costs: None reported. Cause: The College was not aware of the Program Enrollment screen in NSLDS and therefore, was not checking the accuracy of the information. Related to the program begin date, the school was reporting the date of the change, not the date the student began taking courses for the program. The College was not aware of the requirement that a student needs to be certified at least every 60 days. For the one student with the incorrect enrollment dates the student had an incomplete course on the last course needed to graduate, therefore, was properly reported as withdrawn at that point. However, the student completed the course and should have been changed to ?graduate? status, however, this was not done. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat Finding: No Recommendation: We recommend that the College implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution. View of Responsible Official: The College agrees with the finding.

Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Fund (HEERF) CFDA Number: 84.425E ? HEERF Student Aid Portion Award Period: July 1, 2019 to June 30, 2020 Type of Finding: - Compliance, Other Matter - Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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, the initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Condition and Context: During our testing of the reporting process, we were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner. In addition, we noted the initial report was not submitted within the 30-day required time frame. Questioned costs: None reported. Cause: A control system to prevent and detect errors in the reporting process was not created at the time the reports were filed. The College was not able to submit the report with in the 30 days due to the limited staffing as a result of the pandemic. Effect: It was possible for errors to occur and not be caught in a timely manner. The report was submitted after the 30-day time frame. Repeat Finding: No Recommendation: We recommend someone other than the preparer of the reports review the reports for accuracy prior to submission. We also recommend the College establish a system to track due dates of reports to ensure timely submission. View of Responsible Official: The College agrees with the finding.

Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Fund (HEERF) CFDA Number: 84.425E ? HEERF Student Aid Portion Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Based on guidance provided by the Department of Education, each institution is required to create a documented distribution plan for the recipients of the student portion of the CARES Act funding. Condition and Context: The College?s criteria on their distribution plan for students who could receive aid included a requirement that the student must be enrolled in on-campuses courses. During our testing of forty (40) students who received payments from this grant, one student was found to be enrolled exclusively in online courses. Questioned costs: None reported. Cause: This student was missed when the College reviewed the list of students to determine eligibility based on the criteria in their distribution plan. Effect: The College did not follow their distribution plan. Repeat Finding: No Recommendation: We recommend the College evaluate the procedures they have in place to determine eligibility and make revisions to help insure they follow the criteria in their distribution plan. View of Responsible Official: The College agrees with the finding.

Federal Agency: Economic Development Administration Federal Program Title: Investments for Public Works and Economic Development Facilities CFDA Number: 11.300 ? Public Works and Economic Development Facilities Program Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal 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 reporting process, we were unable to identify a specific control in place to ensure that any errors would be prevented or detected in a timely manner for the quarterly progress reports. Of the two quarterly special reports tested, we noted there was no review and approval documented. Questioned costs: None reported. Cause: A control system to prevent and detect errors in the quarterly progress reporting process was not created at the time the reports were filed. Effect: It was 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 quarterly progress reports review the reports for accuracy prior to submission. View of Responsible Official: The College agrees with the finding.

Federal Agency: Economic Development Administration Federal Program Title: Investments for Public Works and Economic Development Facilities CFDA Number: 11.300 ? Public Works and Economic Development Facilities Program Award Period: July 1, 2019 to June 30, 2020 Type of Finding: - Compliance, Other Matter - Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 29 CFR part 5, contractor or subcontractor are required to submit to the non-federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a certified statement of compliance. Condition and Context: During our testing of the requirement for weekly submission of payroll reports, we noted the weekly payroll reports were submitted monthly instead of weekly as required. In addition, we noted 6 of the 55 weekly payroll reports did not have a signed certified statement of compliance. Questioned costs: None reported. Cause: The College was not aware of the requirement to receive the reports weekly, and they did not ensure that each of the weekly reports submitted had a signed certificate of compliance. Effect: Although the College received weekly reports, the College was not in compliance with the requirements to obtain these reports weekly from the contractor/subcontractor and making sure all payrolls submitted had the certified statement of compliance. Repeat Finding: No Recommendation: We recommend the College request the contractors/subcontractors to submit the payroll reports weekly and to ensure the payroll has the certified statement of compliance. View of Responsible Official: The College agrees with the finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Number: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 ? June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Federal regulations require all tuition, books, and room and board be included in the calculation of Title IV Refunds. Condition: Some tuition, books, and room and board were not included in the cost of attendance for the Title IV Refunds. Questioned costs: $1,366 Context: 1 of 40 students tested were not calculated correctly. The business office and the financial aid office calculated the R2T4 for every student who withdrew before the 60% cutoff. Cause: Due to the system separating tuition and books from the room and board costs, the room and board costs were excluded from one student?s calculation from the business office and the financial aid office. Effect: The College is not in compliance with the federal regulations requiring the Title IV refunds to include all costs. In addition, the College did not refund the correct amount of loans. Repeat Finding: No Recommendation: We recommend the College put a process in place to ensure that all costs are included in the calculation. This could be a checkbox for each code to ensure the person calculating the refund has looked in every place. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Title: Student Financial Assistance Cluster CFDA Number: 84.063 ? Federal Pell Grant Program 84.007 ? Federal Supplemental Educational Opportunity Grants 84.033 ? Federal Work-Study Program 84.268 ? Federal Direct Loans Award Period: July 1, 2018 ? June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: GLBA (Public Law 106-102) (16 CFR 314) The Federal Trade Commission considers Title IV -eligible institutions that participate in Title IV Educational Assistance Programs as "financial institutions" and are subject to GLBA (16 CFR 313.3(k)(2)(iv). Condition: An Information Security Program has not been formally established. Additionally, a comprehensive risk assessment has not been conducted in accordance with 16 CFR 314.4 (b). Questioned costs: None Context: Documentation requested was not established or able to be provided during the period. Cause: Much work was accomplished towards bringing the college into compliance, however, staff were not fully aware of all the specific components of the GLBA requirements and what documentation should be provided during the audit process. Effect: The College is not in compliance with the federal regulations requiring the institution to establish an information security program and perform a risk assessment. In addition, the College could have unidentified or unacceptable risk leading to the compromise of College systems and/or information. Repeat Finding: No Recommendation: The College should establish an information security program that details security measures which: ? Ensure the security and confidentiality of covered data and information; ? Protect against anticipated threats or hazards to the security or integrity of such information; and ? Protect against unauthorized access to or use of covered data and information that could result in substantial harm or inconvenience to any student, customer, or employee. This Information Security Program should also detail mechanisms to: ? Identify and assess the risks that may threaten covered data and information maintained by the College; ? Develop written policies and procedures to manage and control these risks; ? Implement and review the program; and Recommendation (Continued): ? Adjust the program to reflect changes in technology, the sensitivity of covered data and information and internal or external threats to information security. Furthermore, the College should perform an information technology risk assessment which should be updated on an annual basis. The assessment should identify risks or events by category (financial, operational, strategic, compliance, etc.), assess the risks, and respond to risks. This will allow the institution to better identify, evaluate, and exploit the right risks for their business, all while maintaining the appropriate controls to ensure effective and efficient operations and regulatory compliance. As defined by GLBA - Student Information Security requirements the documented risk assessment must address but not limited to: ? Employee training and management ? Information systems, including network and software design, as well as information sharing processing, storage, transmission and disposal ? Detecting, preventing, and responding to attacks, intrusions, or other system failures. Finally, the institution should have a documented and verified safeguard for each risk identified. Views of responsible officials: There is no disagreement with the audit finding.

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