EIN: 942278279
UEI: KM6FCCTRFY93
Audited by: EIDE BAILLY LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 17, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by June 17, 2025 (443 days ago).
What is a management decision? →FAC accepted this audit on January 30, 2024 — management decision was due July 30, 2024.
Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct 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 Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: 20 of the 35 students we tested did not have their enrollment information for the Spring 2023 term reported to NSLDS. Questioned Costs There were no questioned costs associated with the noncompliance. Context The District disbursed federal financial aid to approximately 1,300 students in the 2022-2023 fiscal year that required student enrollment and program enrollment reporting to NSLDS. A sample of 35 students were selected for testing. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely and accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: (Yes or No) No Recommendation The District 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. Views of Responsible Officials and Corrective Action Plan Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and file name • Link to future transmission page on the National Student Clearinghouse user page • Link to NSDLS Reporting page to validate and confirm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services
Show full finding ▾Hide full finding ▴Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirements: OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct 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 Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: 20 of the 35 students we tested did not have their enrollment information for the Spring 2023 term reported to NSLDS. Questioned Costs There were no questioned costs associated with the noncompliance. Context The District disbursed federal financial aid to approximately 1,300 students in the 2022-2023 fiscal year that required student enrollment and program enrollment reporting to NSLDS. A sample of 35 students were selected for testing. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely and accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: (Yes or No) No Recommendation The District 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. Views of Responsible Officials and Corrective Action Plan Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and file name • Link to future transmission page on the National Student Clearinghouse user page • Link to NSDLS Reporting page to validate and confirm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services
Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and file name • Link to future transmission page on the Na1onal Student Clearinghouse user page • Link to NSDLS Repor1ng page to validate and confirm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services
FAC accepted this audit on January 16, 2023 — management decision was due July 16, 2023.
FAC accepted this audit on March 19, 2022 — management decision was due September 19, 2022.
Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement 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 Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? Thirteen in 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? Three in 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? Four of 60 students did not have enrollment information reported to NSLDS. Questioned Costs There were no questioned costs associated with the noncompliance. Context The District disbursed federal financial aid to approximately 1,300 students in the 2020-2021 fiscal year that required student enrollment and program enrollment reporting to NSLDS. A sample of 60 students were selected for testing. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely and accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: Yes. See prior year finding 2020-005. Recommendation The District 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.
Show full finding ▾Hide full finding ▴Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement 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 Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? Thirteen in 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? Three in 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? Four of 60 students did not have enrollment information reported to NSLDS. Questioned Costs There were no questioned costs associated with the noncompliance. Context The District disbursed federal financial aid to approximately 1,300 students in the 2020-2021 fiscal year that required student enrollment and program enrollment reporting to NSLDS. A sample of 60 students were selected for testing. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely and accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: Yes. See prior year finding 2020-005. Recommendation The District 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 and Corrective Action Plan The Director of Financial Aid will work with the Senior Program Evaluation Specialist to review enrollment reporting processes and procedures to ensure the accuracy of the data reported. Additionally, the frequency of enrollment reporting will be assessed and documented to a reporting calendar to ensure timely and current enrollment reporting to NSLDS.
2020-005
Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007,84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition Significant Deficiency in Internal Control over Compliance - The District did not perform a student information security risk assessment as required by the Gramm-Leach-Bliley Act. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed awards for approximately 1,300 students in 2020-2021 and stores student records for several prior year financial aid student records. Effect The District is out of compliance with 16 CFR 314.4 (b). Cause The District did not implement policies and procedures to comply with student information security required by the Gramm-Leach-Bliley Act during the 2020-2021 fiscal year. Repeat Finding: Yes. See prior year finding 2020-006. Recommendation It is recommended the District designate a person or agency to perform the proper risk assessment required by the Gramm-Leach-Bliley Act to ensure the security of student information.
Show full finding ▾Hide full finding ▴Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007,84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition Significant Deficiency in Internal Control over Compliance - The District did not perform a student information security risk assessment as required by the Gramm-Leach-Bliley Act. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed awards for approximately 1,300 students in 2020-2021 and stores student records for several prior year financial aid student records. Effect The District is out of compliance with 16 CFR 314.4 (b). Cause The District did not implement policies and procedures to comply with student information security required by the Gramm-Leach-Bliley Act during the 2020-2021 fiscal year. Repeat Finding: Yes. See prior year finding 2020-006. Recommendation It is recommended the District designate a person or agency to perform the proper risk assessment required by the Gramm-Leach-Bliley Act to ensure the security of student information.
View of Responsible Officials and Corrective Action Plan Starting FY 2021-22, the Information Technology (IT) department engaged with the California Community College (CCC) Security Center to conduct its annual NIST 800-171 and CIS Critical Security Controls Gap Analysis. In August 2021, the IT department met with Aamir Kahn, Chief Information Security Office of CCC Security Center, to discuss CIS Critical Security Controls Gap Analysis. After the initial meeting, CCC Security Center sent a self-assessment questionnaire that is based on the CIS Critical Security Controls and mapped to the NIST 800-171 standard. This questionnaire will help the District identify what security controls are lacking for compliance with both the NIST 800-171 standard and the CIS Critical Controls. The IT department will submit the completed questionnaire back to CCC Security Center, which will generate a report with the steps necessary to become compliant with the security controls in both the CIS Critical Controls and in NIST 800-17. Based on the report, the Director of Information Technology will develop a plan to resolve any compliance security issues. The District will conduct the NIST 800-171 and CIS Critical Security Controls Gap Analysis on an annual basis. In addition, the IT department is leveraging Microsoft?s 365 security technologies, such as Security Center, Compliance Center, Endpoint Manager, Multi-Factor Authentication, and Microsoft Defender Advanced Threat Protection (ATP). Microsoft?s 365 security technologies enable the IT department to quickly detect, prevent, and respond to attacks, intrusions, or other systems failures.
2020-006
Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act requires that institutions that received a HEERF Section(a)(1) award to publicly post certain information on their website. Specific to the Student Aid Portion of this award, the following information is required, but not limited to, to be published and updated no later than 10 days after the end of each calendar quarter: ? The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act. ? The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition Significant Deficiency in Internal Control over Compliance - During our testing over reporting for the Student Aid Portion, we noted that one of the quarterly reports required to be publicly available 10 days following the end of each quarter was not posted to the District?s website. Questioned Costs There were no questioned costs associated with the condition identified. Context The District was required to complete and post on their website four quarterly reports and one annual report during the 2020-2021 year. Effect The District?s quarterly student aid portions reports were not uploaded to their website with 10 days of the end of the quarter disclosing all of the required information. Cause There was a lack of oversight for the student aid portion reporting for both meeting the required reporting deadline and reporting elements. Repeat Finding: Yes. See prior year finding 2020-003. Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures are in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
Show full finding ▾Hide full finding ▴Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act requires that institutions that received a HEERF Section(a)(1) award to publicly post certain information on their website. Specific to the Student Aid Portion of this award, the following information is required, but not limited to, to be published and updated no later than 10 days after the end of each calendar quarter: ? The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act. ? The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition Significant Deficiency in Internal Control over Compliance - During our testing over reporting for the Student Aid Portion, we noted that one of the quarterly reports required to be publicly available 10 days following the end of each quarter was not posted to the District?s website. Questioned Costs There were no questioned costs associated with the condition identified. Context The District was required to complete and post on their website four quarterly reports and one annual report during the 2020-2021 year. Effect The District?s quarterly student aid portions reports were not uploaded to their website with 10 days of the end of the quarter disclosing all of the required information. Cause There was a lack of oversight for the student aid portion reporting for both meeting the required reporting deadline and reporting elements. Repeat Finding: Yes. See prior year finding 2020-003. Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures are in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
View of Responsible Officials and Corrective Action Plan Beginning Fall of 2021-22, the Director of Financial Aid began oversight of the HEERF reporting website. Oversight included updating the HEERF reporting website with information regarding the Student Aid Portion within 30 days of making awards available to students. Additionally, the Director of Financial Aid began uploading HEERF quarterly reports prepared by the Director of Fiscal Services within ten days of the end of each quarter.
2020-003
FAC accepted this audit on May 16, 2021 — management decision was due November 16, 2021.
Reporting Program Name: COVID-19: CARES Act Higher Education Emergency Relief Funds, Student Portion CFDA Number: 84.425E Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award and update that information every 45 days thereafter. This Section also requires that institutions to report ?The estimated total students at the institution eligible to participate in programs under Section 484 in title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act?. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance - During our testing over reporting for the Student Portion, we noted that the report required to be publicly available 30 days following the award becoming available was late by 60 days and therefore, the District did not meet the timeliness requirement. We also noted that the District did not disclose the number of estimated number of students eligible to receive Emergency Financial Aid Grants to Student under Section 18004(a)(1) of the CARES Act. The number of students who received emergency aid and the amount disbursed as reported on the website, did not agree with District records. Questioned Costs There were no questioned costs associated with the condition identified. Context The District had one report for the Higher Education Emergency Relief Funds, Student Portion due within the year ending June 30, 2020. Effect The District?s 30 day report was uploaded to their website 60 days late and did not disclose all of the required information. Cause There was a lack of oversight for the student aid portion reporting for both meeting the required reporting deadline and reporting elements. Repeat Finding: No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures are in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
Show full finding ▾Hide full finding ▴Reporting Program Name: COVID-19: CARES Act Higher Education Emergency Relief Funds, Student Portion CFDA Number: 84.425E Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award and update that information every 45 days thereafter. This Section also requires that institutions to report ?The estimated total students at the institution eligible to participate in programs under Section 484 in title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act?. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance - During our testing over reporting for the Student Portion, we noted that the report required to be publicly available 30 days following the award becoming available was late by 60 days and therefore, the District did not meet the timeliness requirement. We also noted that the District did not disclose the number of estimated number of students eligible to receive Emergency Financial Aid Grants to Student under Section 18004(a)(1) of the CARES Act. The number of students who received emergency aid and the amount disbursed as reported on the website, did not agree with District records. Questioned Costs There were no questioned costs associated with the condition identified. Context The District had one report for the Higher Education Emergency Relief Funds, Student Portion due within the year ending June 30, 2020. Effect The District?s 30 day report was uploaded to their website 60 days late and did not disclose all of the required information. Cause There was a lack of oversight for the student aid portion reporting for both meeting the required reporting deadline and reporting elements. Repeat Finding: No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures are in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
District Administration will move and update the existing HEERF reporting website to meet the reporting requirements. The website will move to the Financial Aid department; staff in Financial Aid will ensure accurate and timely reporting of student aid in accordance with Federal guidelines on the revised website. District Administration (Executive Vice President) will ensure timely reporting internally and externally as it relates to HEERF student and institutional portion expenditures. Quarterly and annual reports for HEERF will be posted to the website within the required timeframe.
Reporting Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency in Internal Control over Compliance - The process dates reported in the COD files were more than 15 calendar days after the disbursement dates reported in the COD files in the District?s financial records for the Fall and Spring semesters. One of the 60 student disbursements tested was reported to COD in 23 days after the disbursement. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed and reported approximately $6,000,974 in Pell grants to 1,690 students during the year. Effect The District is not in compliance with the federal reporting requirements described in the OMB Compliance Supplement. Cause The District did not report student disbursement records to COD on a timely basis. Repeat Finding: No Recommendation The District should review their procedures and control procedures over COD reporting to ensure timely reporting within the 15-calendar day requirement.
Show full finding ▾Hide full finding ▴Reporting Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency in Internal Control over Compliance - The process dates reported in the COD files were more than 15 calendar days after the disbursement dates reported in the COD files in the District?s financial records for the Fall and Spring semesters. One of the 60 student disbursements tested was reported to COD in 23 days after the disbursement. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed and reported approximately $6,000,974 in Pell grants to 1,690 students during the year. Effect The District is not in compliance with the federal reporting requirements described in the OMB Compliance Supplement. Cause The District did not report student disbursement records to COD on a timely basis. Repeat Finding: No Recommendation The District should review their procedures and control procedures over COD reporting to ensure timely reporting within the 15-calendar day requirement.
The Financial Aid Director and Financial Aid technical analyst, in conjunction with the IT programmer analyst, following the established disbursement calendar, will review Common Origination and Disbursement procedures and control procedures to ensure timely reporting within the 15-calendar day requirement.
Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement 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 institution?s 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 Material Weakness in Internal Control over Compliance - During testing over the NSLDS reporting requirements, it was noted that many student enrollment and program enrollment updates were not timely or accurately to NSLDS. The following are the specific circumstances noted: ? Ten of 60 student enrollment changes tested were noted to have an inconsistent effective date between the college?s system and NSLDS. ? Seven of 60 student enrollment changes tested were reported to NSLDS with an inaccurate enrollment status or no update was made for a particular enrollment change. ? It was noted that no program or enrollment records were reported to NSLDS for one of 60 students tested. ? 44 of 60 student enrollment changes tested were not reported to NSLDS in the required timeframe. Questioned Costs There were no questioned costs associated to the noncompliance. Context Gavilan College disbursed financial aid to approximately 1,700 students in the 2019-2020 fiscal year that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely or accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: No Recommendation The District 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.
Show full finding ▾Hide full finding ▴Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement 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 institution?s 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 Material Weakness in Internal Control over Compliance - During testing over the NSLDS reporting requirements, it was noted that many student enrollment and program enrollment updates were not timely or accurately to NSLDS. The following are the specific circumstances noted: ? Ten of 60 student enrollment changes tested were noted to have an inconsistent effective date between the college?s system and NSLDS. ? Seven of 60 student enrollment changes tested were reported to NSLDS with an inaccurate enrollment status or no update was made for a particular enrollment change. ? It was noted that no program or enrollment records were reported to NSLDS for one of 60 students tested. ? 44 of 60 student enrollment changes tested were not reported to NSLDS in the required timeframe. Questioned Costs There were no questioned costs associated to the noncompliance. Context Gavilan College disbursed financial aid to approximately 1,700 students in the 2019-2020 fiscal year that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS timely or accurately. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: No Recommendation The District 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.
The Financial Aid Director and Financial Aid staff evaluator, in conjunction with the IT programmer and institutional researcher, following the established reporting calendar, will review enrollment reporting procedures and control procedures to ensure timely and accurate reporting to NSLDS.
Special Tests and Provisions ? Gramm-Leach-Bliley Act Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition Material Weakness in Internal Control over Compliance - The District did not perform a student information security risk assessment as required by the Gramm-Leach-Bliley Act. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed awards for approximately 1,700 students in 2019-2020 and stores student records for several prior year financial aid student records. Effect The District is out of compliance with 16 CFR 314.4 (b). Cause The District did not implement policies and procedures to comply with student information security required by the Gramm-Leach-Bliley Act. Repeat Finding: No Recommendation It is recommended the District designate a person or agency to perform the proper risk assessment required by the Gramm-Leach-Bliley Act to ensure the security of student information.
Show full finding ▾Hide full finding ▴Special Tests and Provisions ? Gramm-Leach-Bliley Act Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.003, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Gramm-Leach-Bliley Act because they appear to be significantly engaged in wiring funds to consumers (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the ED and the Gramm-Leach-Bliley Act, institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). Condition Material Weakness in Internal Control over Compliance - The District did not perform a student information security risk assessment as required by the Gramm-Leach-Bliley Act. Questioned Costs There were no questioned costs associated to the noncompliance. Context The District processed awards for approximately 1,700 students in 2019-2020 and stores student records for several prior year financial aid student records. Effect The District is out of compliance with 16 CFR 314.4 (b). Cause The District did not implement policies and procedures to comply with student information security required by the Gramm-Leach-Bliley Act. Repeat Finding: No Recommendation It is recommended the District designate a person or agency to perform the proper risk assessment required by the Gramm-Leach-Bliley Act to ensure the security of student information.
The Director of IT and the IT department will designate an agency to perform the proper risk assessment required by the Gramm-Leach-Bliley Act to ensure the security of student information.
FAC accepted this audit on April 21, 2020 — management decision was due October 21, 2020.
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
FAC accepted this audit on January 15, 2018 — management decision was due July 15, 2018.
FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
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