College of Micronesia-FSM

Finding No.: 2025-001 Federal Agency: U.S. Department of Education AL Program: 84.063/84.033/84.007 Student Financial Assistance Cluster Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Eligibility Questioned Costs: None Criteria: 2 CFR 200.303 (a) states the recipient and subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The College is required to establish internal control to ensure compliance with the following requirements: 34 CFR 676.20 (s) states that: Minimum and maximum Federal Supplemental Educational Opportunity Grants (FSEOG) awards requires: (a) An institution may award an FSEOG for an academic year in an amount it determines a student needs to continue his or her studies. However, except as provided in paragraph (c) of this section, an FSEOG may not be awarded for a full academic year that is— (1) Less than $100; or (2) More than $4,000. Condition: We noted that seven students were awarded amounts exceeding the maximum allowable limit of $4,000, while one student received an award below the minimum allowable amount of $100. Cause: The condition was primarily due to the College’s limited familiarity with FSEOG requirements, as this represents its first year administering the program. As a result, management did not have adequate procedures or guidance in place to ensure compliance with the minimum and maximum award limits prescribed under federal regulations. Effect or potential effect: The College is in noncompliance with applicable requirements. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Finding 2025-001: Eligibility Recommendation: We recommend that management establish and implement formal policies and procedures for the administration of the FSEOG program, including clear guidance on the minimum and maximum award limits in accordance with federal regulations. Management should also provide adequate training to Financial Aid Office personnel on applicable federal requirements, perform supervisory reviews of award calculations prior to disbursement, and conduct periodic monitoring to ensure ongoing compliance with established limits. Response: The College acknowledges the findings resulting from the initial year of the Federal Supplemental Educational Opportunity Grant (FSEOG) program's implementation. The College recognizes that the finding resulted from deficiencies in newly implemented award procedures during the first year of the FSEOG program. In light of this, we wish to provide context regarding the situation and the corrective actions undertaken to address the issue. The seven students identified in this finding were awarded FSEOG funds that reflected their significant financial need and the institution's commitment to enabling students to cover both direct and indirect enrollment costs. An internal review conducted by the Financial Aid Office revealed that these awards inadvertently exceeded the $4,000 annual maximum established by program regulations. Following this internal review, prompt corrective measures were enacted, culminating in the issuance of a formal memorandum to the Comptroller in October of FY26. This memorandum directed adjustments to the affected students’ FSEOG awards to ensure compliance with the prescribed annual maximum. This internal monitoring process underscores the College’s proactive commitment to program integrity and fiscal accountability. Furthermore, the unexpended funds were returned to the U.S. Department of Education during FY26. The College remains dedicated to the proper administration of the FSEOG program and has reinforced its internal review procedures. This includes conducting more frequent audits of award ceilings during active disbursement periods to prevent similar errors in future award years. To address the finding, the College will implement the following actions: 1. Establishment of Formal Policy and Standard Operating Procedures (SOPs): Within 30 days, the College will adopt and implement a dedicated section within the Financial Aid Policy and Procedures Manual specifically for the FSEOG program. This document will delineate federal award limitations, selection criteria based on exceptional financial need groupings, and compliance parameters in accordance with 34 CFR 676.20. 2. Staff Training and Competency Review: Prior to the next award cycle, the College will conduct a mandatory training workshop for all counselors and processing staff within the Financial Aid Office. This training will emphasize the identification of the FSEOG-eligible student population, the applicable selection criteria, and the importance of cross-referencing final award packages. 3. Monitoring and Long-Term Quality Control: The College will implement a mandatory two-tiered verification process. Prior to any FSEOG batch disbursement being sent to the Office of the Comptroller for final payment execution, a senior financial aid officer or director must review and authorize a compliance checklist. This checklist will confirm that there are no boundary violations, and any batch disbursement package containing an amount below $100 or exceeding $4,000 per academic year will be flagged for review. Quarterly compliance reviews will be documented and retained as part of the College's internal control records to verify continued compliance with FSEOG award requirements and to provide supporting documentation for future audits. Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Addressed in Dec 2026

Finding No.: 2025-002 Federal Agency: U.S. Department of Education AL Program: 84.063/84.033/84.007 Student Financial Assistance Cluster Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Verification Questioned Costs: $20,042 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu and indicated on the student’s output documents. Verification tracking groups and verification items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information used to calculate an applicant’s Estimated Family Contribution (EFC) that the institution has reason to believe is inaccurate and provide an accurate code for the individual’s verification status in the Common Origination and Disbursement (COD) system. Condition: The following conditions were observed for 3 out of the 12 students tested out of a total of 25 students requiring verification during the fiscal year. The total amount awarded to these 3 students throughout the year was $20,042, whereas the total amount awarded to all 12 students tested was $83,491. Total amount awarded to all students selected for verification was $127,151. For 3 (or 25%) of 12 students tested, we noted discrepancies in family size between the verification worksheets and the students’ Institutional Student Information Records (ISIR), wherein the family size reflected on the verification worksheets was higher than that reported on the ISIR. Despite these discrepancies identified during the verification process, the ISIRs were not updated or corrected accordingly. Cause: The condition was due to the absence of adequate procedures and review controls to ensure that discrepancies identified during the verification process were properly updated and reflected in the ISIR and reported accurately in the COD system. Effect or potential effect: The College is in noncompliance with applicable verification requirements. Identification as a Repeat Finding: Finding No. 2024-004 Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Finding 2025-002: Special Tests and Provisions: Verification Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response: The College concurs with Finding 2025-002 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Action Responsible Party Target Date Status Reinstate mandatory two-tiered verification file review. No student file in any Verification Tracking Group may be finalized or disbursed without independent review and sign-off by the second FAO staff member. Review logs maintained and submitted monthly to FAO Director. FAO Director/VPEMSS 30 days In progress Implement ISIR Correction Tracking Log. Log captures: date discrepancy identified, date submitted to CPS, CPS confirmation number, and date corrected transaction received. FAO Director reviews weekly. This control directly addresses the gap that led to missed corrections in AY 2024-2025. FAO Director/Student Services Specialist IV 45 days In development Establish mid-year ISIR correction deadline. An internal institutional deadline – set 60 days before the award year closes – will be established to ensure all pending ISIR corrections are submitted before the CPS window closes. FAO Director responsible for tracking FAO Director 30 days Policy and procedure being drafted Mandatory annual FSA verification training for all FAO staff, covering tracking group identification, ISIR-worksheet cross-matching, CPS correction procedures, and the importance of submitting corrections before year-end closure. FAO Director 60 days Scheduled Conduct monthly internal file audits of verified student files. Results reported in writing to the VPEMSS. Shift from quarterly to monthly frequency to ensure errors are caught well before the award year closes. FAO Director 30 days First cycle initiated Revise and redistribute Verification SOP to all FAO staff across all campuses with mandatory sign-off. SOP to include explicit section on ISIR correction deadlines relative to award year closes. FAO Director 30 days In progress Recruit and fill three vacant FAO positions to restore full review capacity FAO Director/VPEMSS/HRO 90 days Recruitment initiated Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit issuance

2024-004

Finding No.: 2025-003 Federal Agency: U.S. Department of Education AL Program: 84.063/84.033/84.007 Student Financial Assistance Cluster Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: NSLDS Reporting Questioned Costs: $-0- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify 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 data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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: For 32, (or 53%), of 60 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 10, (or 17%), of 60 students tested, program level information is not updated in NSLDS. Program-level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status and program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect or potential effect: The College is in noncompliance with applicable enrollment reporting requirements. Identification as a Repeat Finding: Finding No. 2024-007 Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to corrective action plan.

Finding 2025-003: Special Tests and Provisions: NSLDS Reporting Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response: The College concurs with Finding 2025-003 and the auditors’ recommendation. To address this finding, the College has implemented the following actions. Corrective Action Responsible Party Target Date Status Execute formal written agreement between FAO and OARR defining data ownership for each NSLDS record type, update timelines, escalation procedures, and monthly reconciliation responsibilities. Agreement reviewed annually. FAO Director/Registrar/VPEMSS 30 days Draft in progress Implement NSLDS Reporting Calendar aligned to the academic calendar, distributed to FAO, Registrar, and VPEMSS. Built-in reminders at 30, 14, and 7 days before each deadline. FAO Director 30 days Being initiated Implement monthly SIS-to-NSLDS reconciliation. The Financial Aid Office (FAO) will reconcile Student Information System (SIS) data against the NSLDS roster, and any discrepancies will be resolved within five (5) business days. Exception reports will be reviewed and certified monthly by VPEMSS. The monthly reconciliation process will be completed before certification by the VPEMSS, and all identified reporting discrepancies will either be corrected or formally documented with an action plan before certification. FAO Director/Registrar 30 days First cycle underway Coordinate with OARR to verify and maintain accurate CIP codes and credential level data for all active programs at start of each academic year. FAO Director/Registrar 60 days In progress Recruit and fill vacant FAO positions to restore NSLDS processing and monitoring capacity. FAO Director/VPEMSS/HRO 90 days In progress Incorporate NSLDS reporting compliance into annual Title IV self-assessment each August. FAO Director/VPEMSS August 2026 Scheduled Primary Responsible Office: Director, Financial Aid Office Oversight Office: Vice President for Enrollment Management and Student Services Overall CAP Completion Target: Within 90 days of the final audit report issuance; NSLDS record updates within 15 days

2024-007

Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Verification Questioned Costs: $53,441 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information institution has reason to believe is inaccurate and Condition: For 6 (or 19%) of 31 students tested, incorrect verification procedures were performed by the College. Standard verification (V1) was performed instead of the required custom verification (V4). , whereas V4 requires verification their statement of education purpose. For 1 (or 3%) of 31 students tested, verification worksheet is missing and required verification procedure is not performed. For 5 (or 16%) of 31 students tested, discrepancies were found in the verification worksheet versus . For 3 (or 10%) of 31 students tested, corrections required for ISIRs were not made. Cause: The College did not effectively monitor compliance with applicable verification requirements. Effect: The College is in noncompliance with applicable verification requirements. Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding No.: 2024-04 - Special Test and Provisions: Verification Recommendation The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include: • Clear guidelines for identifying and applying the correct verification tracking groups (e.g.,Vl,V4,V5). • Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement. • Steps for submitting timely and accurate ISIR corrections, as required. • A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored. 2. Policy and Procedure Enhancement a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will: • Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center. • Participate in internal refresher workshops focused on hands-on case processing and error prevention. • Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements. 3. Verification Quality Control Protocol a. The FAO will implement a structured quality control protocol for verification, including: • A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness. • Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented. • A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes: • Monitoring the accuracy of verification tracking group assignments and documentation across all campuses. • Tracking the completion of required training for all FAO staff. • Conducting quarterly file audits to verify ongoing compliance with federal verification standards. • Reporting findings and corrective actions quarterly to the VPEMSS). Contact: VPEMSS Completion Date - September 30, 2025

2023-005

Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Gramm-Leach-Bliley Act Student Information Security Questioned Costs: $--- Criteria: The Gramm-Leach-Bliley Act (GLBA) requires 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 Assistrance 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 should 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)). Condition: The College does not have a qualified individual to oversee the GLBA information security program. Additionally, the Company does not have an existing GLBA information security program in place. Cause: The non-compliance is due to a lack of awareness and understanding of the GLBA requirements and the absence of a formalized process for establishing and maintaining an information security program Effect: The College is in noncompliance with applicable GLBA requirements. Recommendation: The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding 2024-05 - Special Tests and Provisions: Gramm-Leach-Bliley Act-Student Information Security Recommendation The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Response The college acknowledges the finding and will strengthen its student information security by implementing the following: 1. Designate a qualified Information Security Officer from within the IT Division or recruit externally if internal capacity is limited. 2) Develop a GLBA compliance program that includes: • Annual risk assessments • Implementation of administrative, technical, and physical safeguards • Staff training on data privacy • Annual testing of the security protocols Contact: Vice President for Institutional Effectiveness & Quality Assurance (VPIEQA) Completion Date: September 30, 2025

2023-006

Finding No.: 2023-007 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Disbursements to or on Behalf of Students Questioned Costs: $--- Criteria: 34 CFR 668.165(a)(1)) requires institutions to notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) prior to making a disbursement. When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition: The College does not provide notification to students regarding the amount and type of Title IV funds they are expected to receive, as well as how and when those disbursements will be made. No questioned cost is identified as the non-compliance was related a notification requirement. within the required 14-day timeframe. No questioned cost is identified as the credit balance was subsequently disbursed to the students. Cause: The non-compliance is due to inadequate processes and controls for communicating financial aid information to students. This includes a lack of established procedures for generating and distributing notifications to students. Effect: The College is in noncompliance with applicable student notification and time frame requirements for paying credit balances to students. Recommendation: The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of award letters or college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day timeframe to maintain compliance with federal regulations. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding 2024-06 - Special Tests and Provisions: Disbursements to or on Behalf of Students Recommendation The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of an award letter of college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day time frame to maintain compliance with federal records. Response The College acknowledges the findings and has initiated a process to address them. A formal request has been submitted to the SIS program developer for the implementation of a notification feature. The SIS vendor has confirmed development will be completed by July 1, 2025. This feature will ensure that students receive email notifications when they are awarded and reimbursed for any overpayments. Furthermore, we will establish an enhanced level of monitoring to ensure that credit balances are disbursed within the designated 14-day timeframe. Contact: Comptroller Completion Date: September 30, 2025

2023-007

Finding No.: 2023-008 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Enrollment Reporting Questioned Costs: $--- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify 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 data on the institution Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two , both of which need to be reported accurately and have separate record types. Condition: For 24 (or 60%) of 40 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 21 (or 53%) 40 students tested, program level information is not updated in NSLDS. Program- level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status, program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect: The College is in noncompliance with applicable enrollment reporting requirements. Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding No.: 2024-07- Special Tests and Provisions: Enrollment Reporting Recommendation The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025

2023-008

Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Verification Questioned Costs: $53,441 Criteria: 34 CFR 668.54(a); FSA Handbook Application and Verification Guide, Chapter 4 requires an institution to establish written policies and procedures that incorporate the provisions of 34 CFR 668.51 through 668.61 for verifying applicant information for those applicants selected for verification by ED. Institutions shall require each applicant whose application is selected by ED to verify the information required for the Verification Tracking Group to which the applicant is assigned. However, certain applicants are excluded from the verification process as listed in 34 CFR 668.54(b). A menu of potential verification items for each award year is published in the Federal Register, and the items to verify for a given application are selected by ED from that menu items for each award year can also be found in the annual FSA Handbook, Application and Verification Guide, Chapter 4. Institutions shall also require applicants to verify any information institution has reason to believe is inaccurate and Condition: For 6 (or 19%) of 31 students tested, incorrect verification procedures were performed by the College. Standard verification (V1) was performed instead of the required custom verification (V4). , whereas V4 requires verification their statement of education purpose. For 1 (or 3%) of 31 students tested, verification worksheet is missing and required verification procedure is not performed. For 5 (or 16%) of 31 students tested, discrepancies were found in the verification worksheet versus . For 3 (or 10%) of 31 students tested, corrections required for ISIRs were not made. Cause: The College did not effectively monitor compliance with applicable verification requirements. Effect: The College is in noncompliance with applicable verification requirements. Recommendation: The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding No.: 2023-005 Recommendation The College should enhance training programs for staff involved in the verification process to ensure they are fully aware of the requirements and procedures. Establish robust internal controls and review mechanisms to ensure that verification worksheets are completed accurately and consistently with ISIRs. Implement a tracking system to ensure that all required corrections to ISIRs are performed in a timely manner. Response The College acknowledges the audit finding regarding verification errors, including the incorrect application of verification tracking groups, missing documentation, discrepancies between verification worksheets and ISIRs, and failure to make required corrections. In response, the Financial Aid Office (FAO) is committed to strengthening its verification procedures to ensure full compliance with federal regulations and to protect the integrity of Title IV funds. To this end, the College will implement the following corrective actions: 1. Policy and Procedure Enhancement a. The FAO will develop and implement a formal Standard Operating Procedure (SOP) for the verification process, revise and update all existing verification worksheet forms. This SOP will include: • Clear guidelines for identifying and applying the correct verification tracking groups (e.g., V1, V4, V5). • Procedures for resolving discrepancies between verification worksheets and ISIRs prior to award disbursement. • Steps for submitting timely and accurate ISIR corrections, as required. • A documentation checklist to ensure all required verification forms and statements of educational purpose are collected and properly stored. 2. Policy and Procedure Enhancement a. To ensure consistent understanding and application of federal verification rules, FAO staff across all campuses will: • Complete mandatory annual training sessions on verification policies, ISIR review, and regularly read updates on the Federal Student Aid (FSA) Knowledge Center. • Participate in internal refresher workshops focused on hands-on case processing and error prevention. • Complete relevant modules from the Federal Student Aid (FSA) training site, including those on verification tracking groups and identity verification requirements. 3. Verification Quality Control Protocol a. The FAO will implement a structured quality control protocol for verification, including: • A two-person verification review system in which one staff member processes the file and another independently reviews it for accuracy and completeness. • Use of a standardized review checklist to ensure all required documents match the ISIR and that any discrepancies are properly resolved and documented. • A log of all verification actions, including corrections submitted to FAFSA Processing System (FPS) and updates made in the student’s file, to support audit readiness. 4. Oversight and Accountability a. The Director of the Financial Aid Office (FAO) will be responsible for overseeing verification compliance and ensuring corrective actions are implemented effectively. This includes: • Monitoring the accuracy of verification tracking group assignments and documentation across all campuses. • Tracking the completion of required training for all FAO staff. • Conducting quarterly file audits to verify ongoing compliance with federal verification standards. • Reporting findings and corrective actions quarterly to the VPEMSS). Contact: VPEMSS Completion Date - September 30, 2025

Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Gramm-Leach-Bliley Act Student Information Security Questioned Costs: $--- Criteria: The Gramm-Leach-Bliley Act (GLBA) requires 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 Assistrance 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 should 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)). Condition: The College does not have a qualified individual to oversee the GLBA information security program. Additionally, the Company does not have an existing GLBA information security program in place. Cause: The non-compliance is due to a lack of awareness and understanding of the GLBA requirements and the absence of a formalized process for establishing and maintaining an information security program Effect: The College is in noncompliance with applicable GLBA requirements. Recommendation: The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding 2023-06 – Special Tests and Provisions: Gramm-Leach-Bliley Act–Student Information Security Recommendation The College should develop and implement a comprehensive GLBA information security program that includes risk assessments, safeguards, and regular testing and monitoring of the effectiveness of these safeguards. A qualified individual with the necessary expertise and authority to oversee the GLBA information security program should also be designated. Provide training to relevant staff on GLBA requirements and the importance of information security. Conduct periodic reviews and updates of the information security program to ensure ongoing compliance with GLBA requirements. Response The college acknowledges the finding and will strengthen its student information security by implementing the following: 1) Designate a qualified Information Security Officer from within the IT Division or recruit externally if internal capacity is limited. 2) Develop a GLBA compliance program that includes: • Annual risk assessments • Implementation of administrative, technical, and physical safeguards • Staff training on data privacy • Annual testing of the security protocols Contact: Vice President for Institutional Effectiveness & Quality Assurance (VPIEQA) Completion Date: September 30, 2025

Finding No.: 2023-007 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Disbursements to or on Behalf of Students Questioned Costs: $--- Criteria: 34 CFR 668.165(a)(1)) requires institutions to notify students of the amount and type of Title IV funds they are expected to receive, and how and when those disbursements will be made (often referred to as an award letter or college financing plan) prior to making a disbursement. When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, room and board, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition: The College does not provide notification to students regarding the amount and type of Title IV funds they are expected to receive, as well as how and when those disbursements will be made. No questioned cost is identified as the non-compliance was related a notification requirement. within the required 14-day timeframe. No questioned cost is identified as the credit balance was subsequently disbursed to the students. Cause: The non-compliance is due to inadequate processes and controls for communicating financial aid information to students. This includes a lack of established procedures for generating and distributing notifications to students. Effect: The College is in noncompliance with applicable student notification and time frame requirements for paying credit balances to students. Recommendation: The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of award letters or college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day timeframe to maintain compliance with federal regulations. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding 2023-07 - Special Tests and Provisions: Disbursements to or on Behalf of Students Recommendation The College should implement a comprehensive communication strategy to ensure that all students receive clear and timely notifications regarding their Title IV funds. This should include the development of award letter of college financing plans that outline the amount and type of funds, as well as the disbursement schedule. Additionally, the College should establish a monitoring system to ensure that credit balances are disbursed within the required 14-day time frame to maintain compliance with federal records. Response The College acknowledges the finding and has initiated a process to address them. A formal request has been submitted to the SIS program developer for the implementation of a notification feature. The SIS vendor has confirmed development will be completed by July 1, 2025. This feature will ensure that students receive email notifications when they are awarded and reimbursed for any overpayments. Furthermore, we will establish an enhanced level of monitoring to ensure that credit balances are disbursed within the designated 14-day timeframe. Contact: Comptroller Completion Date: September 30, 2025

Finding No.: 2023-008 Federal Agency: U.S. Department of Education AL Program: Student Financial Assistance Cluster - 84.063 Federal Pell Grant Federal Award No.: Title IV HEA Program OPE ID 01034300 Area: Special Tests and Provisions: Enrollment Reporting Questioned Costs: $--- Criteria: Institutions are required to report enrollment information under the Pell grant via the National Student Loan Data System (NSLDS). Institutions must review, update, and certify 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 data on the institution Maintenance page, is what NSLDS has as the most recently certified enrollment. There are two , both of which need to be reported accurately and have separate record types. Condition: For 24 (or 60%) of 40 students tested, campus level information is not updated in NSLDS. Campus-level record data elements include OPEID number, enrollment effective date, enrollment status and certification date. For 21 (or 53%) 40 students tested, program level information is not updated in NSLDS. Program- level record data elements include OPEID number, Classification of Instructional Programs (CIP) code, CIP year, credential level, published program length measurement, published program length, program begin date, program enrollment status, program enrollment effective date. Cause: The non-compliance is due to inadequate processes and controls for monitoring and updating students' enrollment status in the NSLDS. This includes delays in processing updates and a lack of oversight to ensure accurate reporting. Effect: The College is in noncompliance with applicable enrollment reporting requirements. Recommendation: The College should develop and implement a formal process for monitoring and updating students' enrollment status in the NSLDS to ensure compliance with reporting requirements. Establish internal controls to track changes in enrollment status and ensure timely updates to the NSLDS. Conduct periodic reviews of the enrollment reporting process to identify and address any inaccuracies or delays. Provide training to relevant staff on the importance of compliance with enrollment reporting requirements and the procedures for accurate and timely updates. Views of responsible officials The College acknowledges the finding. Refer to their corrective action plan.

Finding No.: 2023-008 Recommendation The College acknowledges the finding and is committed to addressing the gaps identified in enrollment reporting to the National Student Loan Data System (NSLDS). We recognize that accurate and timely reporting at both the Campus Level and Program Level is critical to maintaining compliance with U.S. Department of Education Title IV requirements and ensuring that students’ federal financial aid records are correctly reflected. Response 1. The College will retain the FAO as the lead unit responsible for NSLDS enrollment reporting, in alignment with Title IV compliance functions. However, the College will strengthen interdepartmental collaboration by establishing a formal partnership with the Registrar’s Office, which maintains the official record of enrollment data. 2. A shared workflow and communication protocol between the FAO and Registrar’s Office will be developed to ensure timely, accurate updates of both campus-level and program-level data. The Registrar’s Office will be responsible for updating student enrollment data, which serves as the source data for NSLDS reporting. The FAO will extract and upload these reports via the Enrollment Reporting Roster (ERR) on the NSLDS Professional Access portal. 3. The College will implement internal controls to track and verify changes in student enrollment status, program information, and key data elements. These controls will include but by no means limited to: a. A monthly reconciliation process between SIS data and NSLDS records. b. Use of exception reports to flag and resolve inconsistencies or delays. c. Documentation of all update logs for audit purposes. Periodic reviews will be conducted at least once per term to assess the accuracy and completeness of enrollment reporting. Any discrepancies will be promptly addressed and procedures updated as necessary to prevent recurrence. Relevant staff in both the FAO and Registrar’s Office will receive regular training on NSLDS reporting requirements, including proper use of record types (Campus vs. Program Level), enrollment status codes, and certification timelines. Training will emphasize the implications of noncompliance and best practices for accurate reporting. Training logs will be maintained by both the FAO and Registrar’s Office to support accountability and audit-readiness. Contact: VPEMSS Completion Date: September 30, 2025