Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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.
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). 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 allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. 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 2021-102.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. 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 developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations 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 fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. 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.
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).
Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. 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. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).