Audit 295932

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Financial Assistance Listing Numbers: 84.425F Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. ED collected an annual report for HEERF grantees in March 2023 covering calendar year 2022 expenditures. On June 17, 2022, ED announced an updated format for the HEERF Quarterly Report effective for Q2 2022, report to be posted July 10, 2022. The quarterly portion reporting requirements involve publicly posting completed forms conspicuously on the institution’s website. Condition Significant Deficiency in Internal Control over Compliance - The quarters ended September 30, 2022 and December 31, 2022 quarterly public report were selected for testing. 5 of the 6 reports selected for testing were not made publicly available on the District’s website. Questioned Costs There are no questioned costs associated with this finding. Context The District has 3 colleges that were required to post forms covering the aggregate amounts spent for HEERF I, II, and III quarterly, as well as one annual report per college. Effect The quarterly reports were not publicly posted on the District’s website. In addition, the supporting documentation was not available for review. Cause The District did not have internal controls in place to ensure quarterly reports were made publicly available and completed accurately with sufficient supporting documentation. Recommendation The District should implement internal controls to ensure that reporting requirements and deadlines are clearly communicated to all staff.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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 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: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students 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 Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. 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.

Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Financial Assistance Listing Numbers: 84.425F Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. ED collected an annual report for HEERF grantees in March 2023 covering calendar year 2022 expenditures. On June 17, 2022, ED announced an updated format for the HEERF Quarterly Report effective for Q2 2022, report to be posted July 10, 2022. The quarterly portion reporting requirements involve publicly posting completed forms conspicuously on the institution’s website. Condition Significant Deficiency in Internal Control over Compliance - The quarters ended September 30, 2022 and December 31, 2022 quarterly public report were selected for testing. 5 of the 6 reports selected for testing were not made publicly available on the District’s website. Questioned Costs There are no questioned costs associated with this finding. Context The District has 3 colleges that were required to post forms covering the aggregate amounts spent for HEERF I, II, and III quarterly, as well as one annual report per college. Effect The quarterly reports were not publicly posted on the District’s website. In addition, the supporting documentation was not available for review. Cause The District did not have internal controls in place to ensure quarterly reports were made publicly available and completed accurately with sufficient supporting documentation. Recommendation The District should implement internal controls to ensure that reporting requirements and deadlines are clearly communicated to all staff.