Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listing number and name: 84.031 Higher Education?Institutional Aid Award numbers and years: P031S150032, October 1, 2015 through September 30, 2021 P031S150098, October 1, 2015 through September 30, 2021 P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096, October 1, 2020 through September 30, 2025 P031S200281, October 1, 2020 through September 30, 2025 P031C210057, October 1, 2021 through September 30, 2026 P031C210077, October 1, 2021 through September 30, 2026 Federal agency: U.S. Department of Education Compliance requirement: Reporting and special tests and provisions Questioned costs: Unknown Condition?The District did not act in accordance with federal regulations for its 10 endowments established from 2005 through 2021 by 6 of its 10 colleges.1 These endowments were created with Higher Education?Institutional Aid (HEIA) program monies held by its Foundation that ranged in value from $64,129 to $359,019, with a combined fiscal year-end balance of $1.6 million including interest earned. Specifically, we found that the District did not submit 3 of its endowments? annual reports for federal fiscal year October 1, 2020 through September 30, 2021, to the U.S. Department of Education (ED), as required, to certify that these endowment monies were spent in accordance with federal regulations. In addition, for all 4 endowment reports tested, we found the reports did not agree to the Foundation?s records and that no one at the responsible college had reviewed or approved them for accuracy prior to submitting them to ED. Further, in reviewing the reports, we found that the District Office and colleges were not aware of each endowment?s investment performance with the Foundation or whether the Foundation?s investment policies met the federal regulations. Effect?The District?s failure to submit accurate endowment reports and the lack of monitoring over the Foundation?s administration of its endowments increases the risk that ED could terminate the endowments and require the District to reimburse ED for the original endowment balances, including interest earned, if the District spent more of the endowments? income than allowed by federal regulations. We did not note any instances of the District spending more than allowed based on the 4 reports tested. Cause?The District Office indicated that all the endowment reports submitted to ED were prepared by the Foundation and were not reviewed for accuracy before the College certified and submitted them to ED. For the 3 reports not submitted, District management reported that they were unable to submit the reports electronically and have not been successful in their attempts to receive assistance from ED to submit the late reports. In addition, the District?s colleges separately contracted with the District?s Foundation to administer the endowments, which included investing the endowment balances and disbursing a portion of the interest earned for allowable program activities. However, the District did not ensure that the Foundation was aware of the program?s requirements or have a plan for ensuring compliance. Further, the District Office did not have written policies and procedures to monitor the Foundation?s contract and the District?s endowments held with the Foundation, and had not designated anyone to centrally monitor these endowments. Criteria?Federal regulation permits the District to designate its Foundation to invest and raise monies for the program?s endowments; however, the District is ultimately responsible for ensuring its endowments are administered in accordance with all federal regulations (34 CFR ?628.3). The District is required to monitor the Foundation?s compliance with all federal requirements, including those that specify the investment types and risks allowed, require the endowments? corpuses remain unspent during the grant award period, ensure it spends no more than 50 percent of the endowments? earnings in accordance with the endowments? purpose, and verify that endowment income is properly calculated and invested in a savings account or low-risk securities (34 CFR ??628.43 through .46). Additionally, federal regulation and the District colleges? federal program award terms require the District to submit annual reports for each of its endowments certifying that the endowments comply with federal regulations (34 CFR ?628.47[f]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District Office should develop and implement written policies and procedures to: 1. Update its endowment contracts with the Foundation to include provisions that: a. Require the Foundation to provide information on each endowment to the District for inclusion in the annual reports. b. Specify the types of investments and investment risks allowed by federal regulations. c. Require the Foundation to provide periodic reporting to the District Office and applicable colleges about the endowments? investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations. 2. Designate an employee to centrally monitor the endowments with the Foundation to ensure the endowments are properly accounted for, spent, and invested in accordance with federal regulations. 3. Ensure that the District?s required endowment annual reports are certified and submitted to ED by the District only after the reports have been reviewed and approved for accuracy and agreement to the Foundation?s records by the responsible District employee. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-104. 1 The endowment grant award numbers and years are as follows: P031010003, October 1, 2001 through September 30, 2006; P031S080044, October 1 2007 through September 30, 2012; P031S080118, October 1, 2008 through September 30, 2014; P031S090050, October 1, 2009 through September 30, 2014; P031A110194, October 1, 2011 through September 30, 2016 (2 endowments); P031A110200, October 1, 2011 through September 30, 2017; P031S150085, October 1, 2015 through September 30, 2020; P031S150098, October 1, 2015 through September 30, 2021; and P031S160090, October 1, 2016 through September 30, 2023.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listing number and name: 84.031 Higher Education?Institutional Aid Award numbers and years: P031S150032, October 1, 2015 through September 30, 2021 P031S150098, October 1, 2015 through September 30, 2021 P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096, October 1, 2020 through September 30, 2025 P031S200281, October 1, 2020 through September 30, 2025 P031C210057, October 1, 2021 through September 30, 2026 P031C210077, October 1, 2021 through September 30, 2026 Federal agency: U.S. Department of Education Compliance requirement: Reporting and special tests and provisions Questioned costs: Unknown Condition?The District did not act in accordance with federal regulations for its 10 endowments established from 2005 through 2021 by 6 of its 10 colleges.1 These endowments were created with Higher Education?Institutional Aid (HEIA) program monies held by its Foundation that ranged in value from $64,129 to $359,019, with a combined fiscal year-end balance of $1.6 million including interest earned. Specifically, we found that the District did not submit 3 of its endowments? annual reports for federal fiscal year October 1, 2020 through September 30, 2021, to the U.S. Department of Education (ED), as required, to certify that these endowment monies were spent in accordance with federal regulations. In addition, for all 4 endowment reports tested, we found the reports did not agree to the Foundation?s records and that no one at the responsible college had reviewed or approved them for accuracy prior to submitting them to ED. Further, in reviewing the reports, we found that the District Office and colleges were not aware of each endowment?s investment performance with the Foundation or whether the Foundation?s investment policies met the federal regulations. Effect?The District?s failure to submit accurate endowment reports and the lack of monitoring over the Foundation?s administration of its endowments increases the risk that ED could terminate the endowments and require the District to reimburse ED for the original endowment balances, including interest earned, if the District spent more of the endowments? income than allowed by federal regulations. We did not note any instances of the District spending more than allowed based on the 4 reports tested. Cause?The District Office indicated that all the endowment reports submitted to ED were prepared by the Foundation and were not reviewed for accuracy before the College certified and submitted them to ED. For the 3 reports not submitted, District management reported that they were unable to submit the reports electronically and have not been successful in their attempts to receive assistance from ED to submit the late reports. In addition, the District?s colleges separately contracted with the District?s Foundation to administer the endowments, which included investing the endowment balances and disbursing a portion of the interest earned for allowable program activities. However, the District did not ensure that the Foundation was aware of the program?s requirements or have a plan for ensuring compliance. Further, the District Office did not have written policies and procedures to monitor the Foundation?s contract and the District?s endowments held with the Foundation, and had not designated anyone to centrally monitor these endowments. Criteria?Federal regulation permits the District to designate its Foundation to invest and raise monies for the program?s endowments; however, the District is ultimately responsible for ensuring its endowments are administered in accordance with all federal regulations (34 CFR ?628.3). The District is required to monitor the Foundation?s compliance with all federal requirements, including those that specify the investment types and risks allowed, require the endowments? corpuses remain unspent during the grant award period, ensure it spends no more than 50 percent of the endowments? earnings in accordance with the endowments? purpose, and verify that endowment income is properly calculated and invested in a savings account or low-risk securities (34 CFR ??628.43 through .46). Additionally, federal regulation and the District colleges? federal program award terms require the District to submit annual reports for each of its endowments certifying that the endowments comply with federal regulations (34 CFR ?628.47[f]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District Office should develop and implement written policies and procedures to: 1. Update its endowment contracts with the Foundation to include provisions that: a. Require the Foundation to provide information on each endowment to the District for inclusion in the annual reports. b. Specify the types of investments and investment risks allowed by federal regulations. c. Require the Foundation to provide periodic reporting to the District Office and applicable colleges about the endowments? investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations. 2. Designate an employee to centrally monitor the endowments with the Foundation to ensure the endowments are properly accounted for, spent, and invested in accordance with federal regulations. 3. Ensure that the District?s required endowment annual reports are certified and submitted to ED by the District only after the reports have been reviewed and approved for accuracy and agreement to the Foundation?s records by the responsible District employee. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-104. 1 The endowment grant award numbers and years are as follows: P031010003, October 1, 2001 through September 30, 2006; P031S080044, October 1 2007 through September 30, 2012; P031S080118, October 1, 2008 through September 30, 2014; P031S090050, October 1, 2009 through September 30, 2014; P031A110194, October 1, 2011 through September 30, 2016 (2 endowments); P031A110200, October 1, 2011 through September 30, 2017; P031S150085, October 1, 2015 through September 30, 2020; P031S150098, October 1, 2015 through September 30, 2021; and P031S160090, October 1, 2016 through September 30, 2023.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.