Finding 388300 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: The District improperly disbursed $6,000 in CSLFRF grants to 2 ineligible students.
  • Impacted Requirements: The District failed to follow eligibility criteria set by the California Community Colleges Chancellor’s Office.
  • Recommended Follow-Up: Implement stronger controls and procedures to ensure only eligible students receive CSLFRF aid.

Finding Text

Allowable Costs & Activities Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department ofthe Treasury Pass-Through Entity: California Community Colleges Chancellor's Office Criteria or Specific Requirements The Uniform Guidance Cost Principals described in 31 CFR Part 35, Subpart A, established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) to support governments in their response to and recovery from the COVID-19 public health emergency. As outlined in the Final Rule set forth by the U.S. Department of the Treasury, to identify eligible uses of funds, recipients should (1) identify a COVID-19 public health or economic impact on an individual or class (i.e., a group) and (2) design a program that responds to that impact. As a recipient of CSLFRF funding, the California Community Colleges Chancellor’s Office (CCCCO) utilized the funding to provide emergency financial assistance grants to low-income students, enrolled at the California community colleges, who had been disproportionally impacted by the COVID-19 public health emergency. The CCCCO established the following eligibility criteria for students to receive CSLFRF grants: • U.S. citizen or eligible non-citizen • Current enrollment in credit or noncredit courses at a California community college • Demonstrate an emergency financial aid need • Qualify as low-income by meeting the requirements to receive a California College Promise Grant (CCPG} or is projected to receive a CCPG for the upcoming term Condition Significant Deficiency – The District disbursed CSLFRF grants to 2 ineligible students out of the 23 students tested. Questioned Costs During our testing, we identified that the District disbursed $6,000 in CSLFRF to 2 ineligible students out of the 23 students tested. Context The District disbursed CSLFRF grants to 115 students during the fiscal year totaling $336,724 in aid. Effect Without proper monitoring of the eligibility requirements set forth by the pass-through entity, the District is at risk of noncompliance with the above referenced criteria. Cause The District did not comply with the most up-to-date student eligibility requirements set forth by the California Community College Chancellor’s Office. Recommendation It is recommended that District establish effective controls and procedures to ensure that funds are only being distributed to those who are eligible to receive CSFRF student aid.

Corrective Action Plan

Response Two different sets of guidelines were issued for the Coronavirus State and Local Fiscal Recovery Funds. The first set of guidelines were issued in March 2021 (Attachment A). These first set of guidelines allowed undocumented students to receive the award #4 (Attachment A). These are the guidelines that were used to award students monies from this fund. During the audit, it was noted that SBCC incorrectly awarded undocumented students with monies from the Coronavirus State and Local Fiscal Recovery Funds. SBCC was not aware at the time of awarding these monies that a second guidance memo had been issued by the Community Colleges of California Chancellor’s Office (CCCCO) on Friday, January 21,2022 (Attachment B). The updated memo clearly stated that undocumented students were no longer eligible for these funds. SBCC had not updated its protocols to match the second memo due to staffing issues within th e financial aid office. Specifically, the manager of the Financial Aid Office was out on disability leave from January 26 through September 28, 2022. However, no funds were awarded during this absence. Within the new guidance, a new process stated how to corrects awards given to candidates originally eligible (undocumented students) under the first memo, but no longer eligible under the second memo. Per the second memo, any incorrectly awarded funds under the first policy were to be replaced with other funds that undocumented students are eligible to receive. Corrective Action To correct the incorrect awarding of funds to ineligible candidates, SBCC cancelled the awards to now ineligible recipients of Early Action Fund (EMASS/SRFR) and replace d them with awards from AB19 monies, which were rolled over from 22-23. SBCC also used monies from remaining HEERF/CARES funds, which allowed for awards to undocumented students. In total, SBCC corrected 16 awards totaling $48,000. SBCC’s records now reflect that no undocumented students received Coronavirus State and Local Fiscal Recovery Funds. Going forward, SBCC is now awarding under the correct guidelines. No further awards have been made to undocumented students. The fund is winding down and will be spent in full by the end of the 23-24 fiscal year.

Categories

Questioned Costs Subrecipient Monitoring Eligibility Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 964742 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $9.04M
84.268 Federal Direct Student Loans $3.97M
21.027 Coronavirus State and Local Fiscal Recovery Funds $336,724
84.002 Adult Education - Basic Grants to States $315,320
84.007 Federal Supplemental Educational Opportunity Grants $300,293
84.048 Career and Technical Education -- Basic Grants to States $223,417
84.033 Federal Work-Study Program $134,196
84.031 Higher Education_institutional Aid $76,409
84.425 Education Stabilization Fund $50,923
17.270 Reintegration of Ex-Offenders $33,755
93.658 Foster Care_title IV-E $32,019
10.558 Child and Adult Care Food Program $13,728
47.070 Computer and Information Science and Engineering $12,440
93.558 Temporary Assistance for Needy Families $7,100
47.076 Education and Human Resources $4,528
12.006 National Defense Education Program $4,441