South Suburban College - Community College District 510Higher Education

FINDING 2025-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally, per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete the Fiscal Operations Report and Application to Participate (FISAP). Condition During our compliance testing we noted 12 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 12 students’ disbursement information was submitted between 106 and 114 days late. These were for students during the Summer and Fall semester, there were no late submissions noted for the Sping Semester. However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of support for the amounts. Thus the College was not in compliance with the reporting requirements. Cause The cause appears to be due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2024-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations. We also recommend retaining documentation to support amounts within the FISAP. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2025-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: $268 Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted 1 out of the 7 students selected for testing had their total term days incorrectly calculated by the College. However, this student was not required to have aid returned. This was for the Summer 2024 semester; there were no incorrectly calculated days noted from our testing of Fall 2024 and Spring 2025 students. Additionally, we noted 1 student of 7 selected from the Fall 2024 semester testing did not have their aid of $268 returned. We additionally noted that review of the students’ worksheets was not properly documented. Questioned Costs None Context A sample of 7 students were selected for compliance testing. 1 student did not have their total term days calculated correctly and 1 student did not have their aid returned. Effect When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be returned is incorrectly calculated. Additionally, lack of documented review of calculations could lead to incorrectly calculated days and unreturned aid. Cause The cause appears to be an error in the processing of the information, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2024-003. Recommendation We are aware that the Student Financial Aid Department updates to its procedures term days calculations and return of funds determination. We recommend that the College continue these efforts to ensure future compliance with all applicable return of funds requirements. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2024-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT; FISCAL OPERATIONS REPORT AND APPLICATION TO PARTICIPATE Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guidance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Additionally, per the requirements of the Uniform Guidance in the Compliance Supplement, the College is to complete the Fiscal Operations Report and Application to Participate (FISAP). Condition During our compliance testing we noted 11 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 11 students’ disbursement information was submitted between 12 and 151 days late. However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Additionally, we noted that the College was unable to provide support for amounts included in the FISAP. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved. We were also unable to complete FISAP testing due to lack of support for the amounts. Thus the College was not in compliance with the reporting requirements. Cause The cause appears to be due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2023-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations. We also recommend retaining documentation to support amounts within the FISAP. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the year was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Questioned Costs None Context The College initially provided a population of students that included students that were flagged as requiring a return of funds calculation incorrectly. However, the College eventually did produce a population which was subject to control and compliance testing that based on the selections tested, included students who were correctly flagged as requiring return of funds calculations. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2023-002. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Assistance Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted 4 out of the 8 students selected for testing had their total term days incorrectly calculated by the College. Due to this, incorrect amounts were returned. See questioned costs below. Additionally, 5 out of the 8 students tested did not receive their return of funds within 45 days, with dates ranging from 4 months late to 14 months late. Questioned Costs $12,400 (Known questioned costs of $1,240; likely questioned costs $11,160). Context A sample of 8 students were selected for compliance testing. 5 students’ did not have their total term days calculated correctly, which lead to the incorrect amount of funds required to be returned being determined. Additionally, 4 of the 8 students sampled did not receive their funds returned within 45 days. Effect When the total term days are incorrectly calculated, there is a risk that the amount of funds required to be returned is incorrectly calculated. Cause The cause appears to be an error in the processing of the information, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures term days calculations and return of funds determination. We recommend that the College continue these efforts to ensure future compliance with all applicable return of funds requirements. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2023-001 – CONTROLS AND NONCOMPLIANCE OVER REPORTING – PELL COMMON ORIGINATION AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within 15 days. Condition During our compliance testing we noted 5 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 15 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 5 students’ disbursement information was submitted between 15 and 83 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2022-001. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2023-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – NATIONAL STUDENT LOAN DATA SYSTEM Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds has a change in status such as increase/decrease in attendance levels, graduation, or withdrawal, the institution must submit the status change information to the Department of Education’s National Student Loan Data System (NSLDS) site within 60 days. Condition During our testing of controls over reporting it is noted that the College could not locate documentation for 3 out of 25 students selected for testing to support their change in status that was reported to the NSLDS. Additionally, during our compliance testing we noted 3 out of 25 students selected for testing where the College submitted the status information to the NSLDS site after the 60 day submission window. Questioned Costs None Context A sample of 25 students were selected for compliance testing. 3 students’ status information was submitted between 35 and 43 days late However, for these students, it was noted during our compliance testing that the status information reported by the College to the U.S. Department of Education was accurate. Additionally, the College was unable to locate its enrollment status change documentation that the NSLDS site indicated had occurred for 3 additional students out of the 25 selected for testing. Effect The College did not apply its established controls to ensure SSCR information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is not considered a repeat finding. Recommendation We recommend that the College’s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the SSCR information. This may including automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Federal Department: Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition During our compliance testing, we noted that the College’s population of students identified as being subject to the return of funds for the Fall 2022 semester was not correct, as it included students that were flagged as requiring a return of funds calculation incorrectly. Additionally, the College was unable to provide support to verify that the funds returned to the Department of Education due to Department of Education’s new G6 system that did not maintain archived submission information. Questioned Costs None Context The College was unable to produce a revised population for the Fall 2022 semester. However, the College did produce an accurate population for the other semesters in the fiscal year which was subject to control and compliance testing. The College’s Colleague system did maintain the return of funds date which was in compliance with requirements, but that information could not be independently verified. Effect Without an accurate population, there could be a risk that control procedures applied by the College as well as compliance with requirements for return of funds calculations may not be complete due to missing information. Cause The cause appears to be an error in the processing of the file documentation would properly identify students in the return of funds population in the Fall 2022 semester as well as access to the archived Department of Education submissions. Identification as a Repeat Finding, if Applicable This matter is not considered a repat finding. Recommendation We are aware that the Student Financial Aid Department updates to its procedures regarding documentation retention and population determination. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements, including maintenance of an accurate population for all semesters in which students are subject to certain compliance requirements such as return of funds. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2022-001 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Per the requirements of the Uniform Guiance in the Compliance Supplement, the College is required to maintain documentation demonstrating its controls over compliance with applicable federal requirements. Additionally, Federal regulations dictate when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education?s Common Origination and Disbursement (COD) site within 15 days. Condition During our testing of controls over reporting it is noted that the College did not maintain proper documentation in the form of a list of files that are reviewed by the Student Financial Aid Director for accuracy before being submitted to the COD. Additionally, during our compliance testing we noted 8 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 30 day submission window. Questioned Costs None Context The College was unable to locate its control documentation that COD site submissions were reviewed for accuracry and approved prior to submission. A sample of 25 students were selected for compliance testing. 8 students? disbursement information was submitted between 3 and 17 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely as well as properly reviewed and approved, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2021-003. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2022-002 ? CONTROLS AND NONCOMPLIANCE OVER ELIGIBILITY AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063 Program Name(s): Student Financial Aid Cluster Questioned Costs: $500 Criteria Per the Uniform Guidance Compliance Supplement, Federal Suppleental Educational Opportunity Grants (FSEOG) are awarded first to Pell receipts who have the lowest expected family contributions. If an institution has FSEOG funds remaining after giving FSEOG awards to all the Federal Pell Grant recipients at the institution, the institution shall award the remaining FSEOG funds to those eligible students with the lowest expected family contributions who will not receive Federal Pell Grants. Condition During our compliance testing two students received FSEOG funding while having an expected family contribution greather than $0, which would indicate that other Pell receipients had potential need but were not awarded aid. Questioned Costs The known questioned costs were determined by obtaining the amount of FSEOG financial aid that the students were awarded per the College?s student financial aid population. Context The College could not locate documentation to support the reason these students were judgementally awarded the FSEOG funds. Effect There is a possibility that the students who received financial aid were not actually eligible for the amounts received. Cause The cause appears to be an error in the processing of the file documentation would include support for why the FSEOG award was granted even though the student did not have the lowest possible expected family contribution. Identification as a Repeat Finding, if Applicable This is a partial repeat finding. This was reported in the prior year as finding 2021-002. Recommendation We are aware that the Student Financial Aid Department is undergoing updates to its procedures regarding documentation retention. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2021-002 ? CONTROLS AND NONCOMPLIANCE OVER ELIGIBILITY AND DISBURSEMENT Federal Department: Department of Education Assistance Listing Number(s):84.063 Program Name(s): Student Financial Aid Cluster Questioned Costs: $2,248 Criteria Per the requirements of the Uniform Guidance in the Compliance Supplement, the College is required to maintain all documentation necessary to demonstrate compliance with student financial aid provisions. Condition During our control and compliance testing, one selection in our sample was unable to be located and thus testing could not be completed for controls and compliance. Questioned Costs The known questioned costs were determined by obtaining the amount of Pell financial aid that the student was awarded per the College?s student financial aid population. Context When performing eligibility and disbursement testing over student financial aid, the College was unable to locate a student file selected for testing out of 60 sampled. However, we noted no other exceptions in controls or compliance over eligibility and disbursement in the other items tested. Effect There is a possibility that the student who received financial aid was not actually eligible for the amounts received. Cause The cause appears to be an error in the processing of the file documentation, due to turnover in the Student Financial Aid department, as well as interruptions of activities caused by the COVID-19 pandemic that began in March 2020 that caused interruptions of staffing. Identification as a Repeat Finding, if Applicable This matter is not considered to be a repeat finding. Recommendation We are aware that the Student Financial Aid Department is undergoing updates to its procedures regarding documentation retention. We recommend that the College continue these efforts to ensure future compliance with all applicable documentation requirements. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2021-003 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Federal Department: Department of Education Assistance Listing Number(s):84.063, 84.007, 84.033 Program Name(s): Student Financial Aid Cluster Questioned Costs: None Criteria Federal regulations dictate when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education?s Common Origination and Disbursement (COD) site within 30 days. Condition During our compliance testing we noted 22 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 30 day submission window. Questioned Costs None Context A sample of 25 students were selected for testing. 22 students? disbursement information was submitted between 6 and 124 days late However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter is considered a repeat finding, and was reported previously as finding 2020-004. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2021-004 ? CONTROLS AND NONCOMPLIANCE OVER ALLOWABLE COSTS Federal Department: Department of Education Assistance Listing Number(s):84.425E, 84.425F, 84.425L Program Name(s): COVID 19: Higher Education Emergency Relief Fund Questioned Costs: None Criteria Per the U.S. Department of Education?s FAQ?s guidance published January 14, 2021, Institutions can charge indirect costs to Institutional portion awards using the on-campus rate specified in an institution?s negotiated indirect cost rate agreement. If the institution does not have a negotiated indirect cost rate, the de minimis rate of 10% can be used against Modified Total Direct Costs. Institutions must also comply with Title 2 section 200.403 of the CFR and charge such costs consistently as either indirect or direct costs, but may not be double-charged as both. Condition During our testing of institutional allowable costs, it was noted that management had improperly calculated the indirect cost allowance by applying the de minimis rate of ten percent against direct costs already charged to its HEERF grants rather than a pool of Modified Total Direct Costs. Questioned Costs None Context In our sampling of the non-payroll expenditures for the Institutional portion of HEERF funds which included the College?s total indirect cost calculation, the College incorrectly applied the de minimis rate of 10% against various expenditure accounts that have already been charged as direct costs. Management subsequently revised its calculations using the correct cost pool and noted no change in the amount of indirect costs that were permitted to be charged to the grant. Effect The calculation of indirect costs charged to the grant was incorrect. Cause The cause appears to be inadequate review of published requirements and misinterpretations of guidance. Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that management continue to monitor the guidance by the Department of Education as well as the Uniform Guidance compliance supplement to ensure calculations for indirect costs are performed properly. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2021-005 ? CONTROLS AND NONCOMPLIANCE OVER ALLOWABLE COSTS Federal Department: Department of Education Assistance Listing Number(s):84.425E, 84.425F, 84.425L Program Name(s): COVID 19: Higher Education Emergency Relief Fund Questioned Costs: $2,374 Criteria Per the requirements of the Uniform Guidance in the Compliance Supplement, the College is required to maintain all documentation necessary to demonstrate compliance with HEERF provisions. Condition During our testing of the College's institutional payroll expenditures, it was noted that the College did not maintain proper documentation for certain transactions. Questioned Costs The known questioned costs were identified based the total amount of payroll costs selected for testing where supporting documentation was incomplete. Context The College did not maintain proper documentation of (1) the number of COVID-19 related hours worked for 2 out of the 3 employees tested, and (2) Personnel Action Forms or any other HR form to support the hourly rate applied for 1 out of the 3 employees tested. Effect The College did not have documentation to assert compliance with HEERF requirements for the transactions selected. Cause The cause appears to be an error in the application of the College's policies and procedures regarding documentation of allowable costs Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that the College remind employees regarding the requirements for documentation of allowable activities in accordance with applicable grant requirements so that the College can maintain support for compliance for institutional payroll expenditures. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

FINDING 2021-006 ? CONTROLS AND NONCOMPLIANCE OVER REPORTING Federal Department: Department of Education Assistance Listing Number(s):84.425E, 84.425F, 84.425L Program Name(s): COVID 19: Higher Education Emergency Relief Fund Questioned Costs: None Criteria Per the U.S. Department of Education?s Electronic Announcement dated May 13, 2021, regulations were enacted for institutions to comply with Section 314(e) of the CRRSAA and submit an initial report to the Secretary thirty (30) days from the date of the institution's Certification and Agreement to the Department. Each participating institution must post the information on the institution's primary website, as an initial report under Section 314(e) of the CRRSAA. This information must also be updated no later than 10 days after the end of each calendar quarter, with each report presented separately for the calendar quarter reporting period and not on a cumulative basis. Condition During our testing of quarterly reporting of institutional funds received under HEERF, the College had prepared the quarterly reporting by aggregating expenditures and showing such amounts on a cumulative basis, which was not permitted by Department of Education guidelines. Questioned Costs None Context The Department of Education requires institutions to report activity related to HEERF funding on their website. The institutional portion of expenditures are to be posted on a quarterly basis on separate documents by quarter and should not be cumulative. In reviewing the quarterly reports posted on the College's website, it was noted that the quarterly reports had incorrectly aggregated institutional expenditures each quarter and amounts were reported on a cumulative basis. The College subsequently corrected the error and reposted the correct reports after the error was identified. Effect The College reported institutional expenditures on a cumulative basis rather than separate by each calendar quarter. Cause Due to guidance requirements that were updated with the rollout of HEERF II & HEERF III funding, it was not clear to management whether amounts could be reported on a cumulative basis. Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We noted that the College revised the previously posted quarterly reports to correct the errors noted. We recommend that management continually monitor reporting requirements as released by the Department of Education in an effort to ensure compliance due to the continually changing HEERF requirements. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

Criteria Federal regulations dictate an institution not participating under a U.S. Department of Education approved Quality Assurance Program is required to establish written policies and procedures that incorporate the provisions of 34 CFR sections 668.51 through 668.61 for verifying applicant information. Such an institution shall require each applicant whose application is selected by the U.S. Department of Education to verify the information required for the Verification Tracking Group to which the applicant is assigned. Condition Students that are flagged by the U.S. Department of Education on their Institutional Student Information Record (ISIR) form for verification require verification to be performed. During our control testing, we noted that 45 of the 60 students selected did not have their verification worksheet independently reviewed and approved. Questioned Costs None Context A sample of 60 students were selected for testing. Verification worksheets and supporting documentation were included in the student folders to show that the verification process took place. For the above exceptions, none of the records reviewed required corrections or additional reporting to the U.S. Department of Education, resulting in no adjustments to the aid awarded to the student. Effect The College did not apply its established controls to ensure verification is independently reviewed for accuracy. Cause The cause appears to be an error in the processing of the verification documentation, due to turnover in the Student Financial Aid department, as well as interruptions of activities caused by the COVID-19 pandemic that began in March 2020 that caused interruptions of staffing. Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding documentation of verification controls. This may include considering electronic documentation in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

Criteria Federal regulations dictate when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs and no additional disbursements may be made to the student for the payment period or period of enrollment, per the provisions 34 CFR 668.22(a)(1) through (a)(5)). Condition Controls are required to be in place to ensure the accuracy of calculations per above, called ?Return of Funds? calculations. During our control testing we noted 10 out of 10 students selected for testing where there was no documentation of independent review of the calculations as prescribed by the College?s policies and procedures. Questioned Costs None Context A sample of 10 students were selected for testing. The College normally performs separate review calculations outside of the Colleague system to ensure accuracy of the calculations, using a pre-established form and includes signature of the College manager verifying the accuracy of the calculation. The supporting documentation requested for our sample could not be located. However, it was noted during our compliance testing that the calculations and funds returned by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure return of fund calculations were completed accurately and timely to all students selected for testing. Cause The cause appears to be an error in the processing of the return of funds control documentation, due to turnover in the Student Financial Aid department, as well as interruptions of activities caused by the COVID-19 pandemic that began in March 2020 that caused interruptions of staffing. Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding documentation of return of fund calculation controls. This may include considering electronic documentation in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

Criteria Federal regulations dictate when a recipient of Title IV funds received a Pell disbursement, the institution must submit the disbursement information to the Department of Education?s Common Origination and Disbursement (COD) site within 30 days. Condition During our compliance test testing we noted 23 out of 25 students selected for testing where the College submitted the Pell disbursement information to the COD site after the 30 day submission window. Questioned Costs None Context A sample of 25 students were selected for testing. The College normally submits disbursement information in scheduled batches to ensure all information is submitted timely. However, it was noted during our compliance testing that the disbursement information reported by the College to the U.S. Department of Education was accurate. Effect The College did not apply its established controls to ensure Pell COD information was remitted timely, thus the College was not in compliance with the requirements. Cause The cause appears to be an error in the processing of the information batches, due to turnover in the Student Financial Aid department. Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that the College?s Student Financial Aid department consider additional steps to reinforce established policies and procedures regarding timely submission of the COD information. This may including automated reminders, updated calendars and other notification mechanisms in the College?s Colleague system to compliment manual controls to allow for more flexibility in remote working situations, such as those caused by the COVID-19 pandemic. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

Criteria Per the U.S. Department of Education?s Electronic Announcement dated August 31, 2020, regulations were enacted for institutions to comply with Section 18004(e) of the CARES Act and submit an initial report to the Secretary thirty (30) days from the date of the institution's Certification and Agreement to the Department. Each participating institution must post the information on the institution's primary website, as an initial report under Section 18004(e) of the CARES Act. This information must also be updated no later than 10 days after the end of each calendar quarter. Condition The College was unable to provide support for certain required reporting under the CARES Act that was published previously on the College?s external website. Questioned Costs None Context During our testing of reports required in relation to Institutional and Student funds received under the CARES Act, the College was unable to furnish support corroborating the posting of the 30 Day report to the College's website as required and could not provide support to show they posted student funds information in their September 30, 2020 quarterly report website posting (which included information that pertained to the fiscal year ended June 30, 2020). Effect The College could not provide documentation that demonstrated the College was in compliance with the 30-day reporting requirements and the 9/30/2020 quarterly student reporting requirements. Cause Due to guidance requirements that changed due to the rollout of the CARES Act funding, management was not clear on what information was required to be saved for audit documentation Identification as a Repeat Finding, if Applicable This matter was not considered a repeat finding. Recommendation We recommend that the College consider revising its reporting approach for CARES Act in order to appropriately document current and past compliance with requirements, such as maintaining screen shots of reporting information previously on public display or adding links to its existing web page to document past reporting. Views of Responsible Officials and Planned Corrective Actions See Corrective Action Plan.

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