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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
Assistance Listing number
and name: 84.031 Higher Education—Institutional Aid
Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023;
P031S190167, October 1, 2019 through September 30, 2024;
P031S200096 and P031S200281, October 1, 2020 through September 30, 2025;
P031C210057 and P031C210077, October 1, 2021 through September 30, 2026;
P031S220015 and P031S220179, October 1, 2022 through September 30, 2027
Award year: July 1, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirement: Reporting and special tests and provisions
Questioned costs: N/A
Condition—The District did not act in accordance with several federal regulations for its 10 endowments that 6 of the District’s 10 colleges established with Higher Education—Institutional Aid (HEIA) program monies that have been held by its Foundation since 2005. The District’s 10 endowments held with the Foundation ranged in value from $66,200 to $367,000 with a combined fiscal year-end balance of $1.7 million, including interest earned.1 Specifically, based on our review of the 10 required annual endowment reports, we found that the District and colleges did not:
• Submit 1 of the 10 required reports to the U.S. Department of Education to certify that endowment monies were spent in accordance with federal requirements.
• Review and approve 2 of 2 reports tested prior to submitting them to the U.S. Department of Education, and we noted that these 2 reports did not agree to Foundation records.
In addition, we found that the District and colleges were not aware of and did not evaluate each endowment’s investment performance with the Foundation and did not ensure that the Foundation’s investment policies met federal requirements.
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 the U.S. Department of Education could terminate the endowments and require the District to reimburse it 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 2 reports tested.
Cause—The District reported that all the endowment reports submitted to the U.S. Department of Education were prepared by the Foundation and submitted by the colleges. However, the District did not have policies and procedures requiring the colleges to review the reports for accuracy, before they were submitted to the U.S. Department of Education. In addition, the District’s colleges separately contracted with the 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 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 should develop and implement written policies and procedures to:
1. Require the colleges to review reports for accuracy prior to certifying them and submitting them to the U.S. Department of Education.
2. 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 and applicable colleges about the endowments’ investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations.
3. 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.
4. Ensure that the District’s required endowment annual reports are certified and submitted to the U.S. Department of Education 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 2022-104 and was initially reported in fiscal year 2021.
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: P047A171009, September 1, 2017 through August 31, 2022;
P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025;
P047A221154 and P047A221160, September 1, 2022 through August 31, 2027
Federal agency: U.S. Department of Education
Compliance requirement: Eligibility
Questioned costs: $5,612
Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:
• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures.
• For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.
Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:
• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.
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, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2
Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.
Criteria—GateWay Community College’s written policies and procedures require employees 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). 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 colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants.
2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures.
3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.
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 2022-105 and was initially reported in fiscal year 2022.
1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations.
2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)
Cluster name: TRIO Cluster
Assistance Listings numbers and names: 84.042 TRIO—Student Support Services
84.047 TRIO—Upward Bound
Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022;
P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025;
P047A221154 and P047A221160, September 1, 2022 through August 31, 2027
Federal agency: U.S. Department of Education
Compliance requirement: Eligibility
Questioned costs: $5,612
Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:
• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures.
• For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.
Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:
• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.
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, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2
Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.
Criteria—GateWay Community College’s written policies and procedures require employees 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). 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 colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants.
2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures.
3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.
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 2022-105 and was initially reported in fiscal year 2022.
1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations.
2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
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, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirements: Special tests and provisions
Questioned costs: Unknown
Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:
• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days.
• Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.
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 Student Financial Assistance Offices’ 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 to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 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 and did not report student enrollment status changes timely.
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]). 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 its Student Financial Assistance Offices to follow District-wide policies and procedures to:
a. Report accurate student 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. Monitor its Student Financial Assistance 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 2022-101 and was initially reported in fiscal year 2015.
Assistance Listing number
and name: 84.031 Higher Education—Institutional Aid
Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023;
P031S190167, October 1, 2019 through September 30, 2024;
P031S200096 and P031S200281, October 1, 2020 through September 30, 2025;
P031C210057 and P031C210077, October 1, 2021 through September 30, 2026;
P031S220015 and P031S220179, October 1, 2022 through September 30, 2027
Award year: July 1, 2022 through June 30, 2023
Federal agency: U.S. Department of Education
Compliance requirement: Reporting and special tests and provisions
Questioned costs: N/A
Condition—The District did not act in accordance with several federal regulations for its 10 endowments that 6 of the District’s 10 colleges established with Higher Education—Institutional Aid (HEIA) program monies that have been held by its Foundation since 2005. The District’s 10 endowments held with the Foundation ranged in value from $66,200 to $367,000 with a combined fiscal year-end balance of $1.7 million, including interest earned.1 Specifically, based on our review of the 10 required annual endowment reports, we found that the District and colleges did not:
• Submit 1 of the 10 required reports to the U.S. Department of Education to certify that endowment monies were spent in accordance with federal requirements.
• Review and approve 2 of 2 reports tested prior to submitting them to the U.S. Department of Education, and we noted that these 2 reports did not agree to Foundation records.
In addition, we found that the District and colleges were not aware of and did not evaluate each endowment’s investment performance with the Foundation and did not ensure that the Foundation’s investment policies met federal requirements.
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 the U.S. Department of Education could terminate the endowments and require the District to reimburse it 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 2 reports tested.
Cause—The District reported that all the endowment reports submitted to the U.S. Department of Education were prepared by the Foundation and submitted by the colleges. However, the District did not have policies and procedures requiring the colleges to review the reports for accuracy, before they were submitted to the U.S. Department of Education. In addition, the District’s colleges separately contracted with the 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 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 should develop and implement written policies and procedures to:
1. Require the colleges to review reports for accuracy prior to certifying them and submitting them to the U.S. Department of Education.
2. 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 and applicable colleges about the endowments’ investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations.
3. 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.
4. Ensure that the District’s required endowment annual reports are certified and submitted to the U.S. Department of Education 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 2022-104 and was initially reported in fiscal year 2021.
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: P047A171009, September 1, 2017 through August 31, 2022;
P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025;
P047A221154 and P047A221160, September 1, 2022 through August 31, 2027
Federal agency: U.S. Department of Education
Compliance requirement: Eligibility
Questioned costs: $5,612
Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:
• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures.
• For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.
Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:
• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.
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, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2
Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.
Criteria—GateWay Community College’s written policies and procedures require employees 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). 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 colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants.
2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures.
3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.
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 2022-105 and was initially reported in fiscal year 2022.
1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations.
2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)
Cluster name: TRIO Cluster
Assistance Listings numbers and names: 84.042 TRIO—Student Support Services
84.047 TRIO—Upward Bound
Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022;
P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025;
P047A221154 and P047A221160, September 1, 2022 through August 31, 2027
Federal agency: U.S. Department of Education
Compliance requirement: Eligibility
Questioned costs: $5,612
Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:
• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures.
• For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.
Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:
• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.
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, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2
Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.
Criteria—GateWay Community College’s written policies and procedures require employees 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). 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 colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants.
2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures.
3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.
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 2022-105 and was initially reported in fiscal year 2022.
1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations.
2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)