METROPOLITAN COMMUNITY COLLEGE AREAHigher Education

Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 01, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.34, states an institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs and states the required elements that the policy must include. Condition: During our testing, we noted the while the institution did have a policy in place to determine Satisfactory Academic Progress, there were elements required by the Department of Education that were not present in the institutions policy. The policy must specify the pace at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe. In addition, it was not specified in the policy when the students Satisfactory Academic Progress is evaluated. Questioned Costs: None Context: During our testing, it was noted the College did not have all of the required elements in the Satisfactory Academic Progress Policy. Cause: The College’s current process in place was not sufficient to ensure proper requirements were met. Effect: The College was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the College reviews their policies to ensure all requirements from the Department of Education are met. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal agency: U.S. Department of Education Federal program title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution’s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on August 31, 2020. Condition: During our testing of the reporting process, it was noted one of the quarterly reports was not submitted in a timely manner. Questioned Costs: None Context: A robust tracking system was not employed for all the various reporting requirements to ensure reports were submitted timely. Cause: The College did not have a robust system in place to document and track reporting requirements. Effect: Reports were not submitted timely. Repeat Finding: Yes Recommendation: We recommend the College establish a system to ensure reports are submitted in a timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.

2022 ? 001 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: The Department of Education (ED) requires an institution must return to ED (notwithstanding any state law, such as a law that allows funds to escheat to the state) any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent but they do not receive. If a check is returned, or an EFT is rejected, the institution may make additional attempts to disburse the funds, provided that the attempts are made no later than 45 days after the funds were returned or rejected. If the institution does not make an additional attempt to disburse the funds, the funds must be returned before the end of the 45 day period and no later than 240 days from the date of the initial attempt to disburse the funds (34 CFR 668.164(l)). Condition: During our testing, we noted two outstanding checks which related to federal funding which were not returned to the Department of Education within the 240 days. Questioned Costs: None Context: During our testing, it was noted the College failed to return the funds in a timely manner. Cause: The College?s current process in place was not sufficient to ensure proper maintenance of outstanding checks. Effect: The College was not in compliance with FSA regulations. Repeat Finding: No Recommendation: We recommend the College reviews outstanding checks regularly to ensure funds are returned to the Department of Education before 240 days of the original disbursement attempt. Views of Responsible Officials: There is no disagreement with the audit finding.

2022 - 002 Federal agency: U.S. Department of Education Federal program title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425E & F Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. The initial reporting for this grant requires the report to be submitted to the Institution?s website within 30 days of the signed Certification Agreement or 30 days after the electronic announcement dated May 6, whichever is later. Institutions were then required to update their websites every 45 days after initial upload. This was changed to quarterly on 8/31/2020. Condition: During our testing of the reporting process, it was noted the student reporting items were not included on one webpage but were found on multiple webpages. Questioned Costs: None Context: A robust tracking system was not employed for all the various reporting requirements included documentation of review and maintenance of records or recorded numbers. Cause: The College did not have a robust system in place to document and track reporting requirements. Effect: Inaccurate reporting on the College's website. Repeat Finding: No Recommendation: We recommend the College establish a system to retain documents to support the accuracy of the reports. Views of Responsible Officials: There is no disagreement with the audit finding.

2021 ? 001 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.268 ? Federal Direct and Plus Education Loan Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.165(a)(2) requires notification be sent to students no earlier than 30 days before the disbursement and no later than 30 days after the Direct Loans are disbursed to their accounts if the College obtains active confirmation. If the College does not obtain active confirmation, notifications are required to be sent no earlier than 30 days before the disbursement and not later than seven days to the student when loan funds are disbursed to their accounts. Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our testing, we noted that 9 of 40 students tested did not receive disbursement notifications before the required deadline established by the US Department of Education. Questioned costs: None Context: The College had a process to email disbursement notices via the financial aid department email account. The College?s IT Department was unable to recover the emails from the department mailbox. The nine exemptions represented $26,935 out of a total $42,737 tested. Total direct loan expenditures for the year ended June 30, 2021 were $4,684,473. Cause: Lack of oversight by management to verify the notifications were sent within the required timeframe and no documentation was retained. Effect: Student may not have been aware of when their federal aid was disbursed and therefore may not know their rights to be able to return loan funds. The College is not in compliance with US Department of Education requirements. Repeat Finding: No Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters being sent is maintained. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 002 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(l)(7) requires the College document a student?s academic attendance including that the activity is academic or academically related and the student?s attendance at the activity. Condition: During our testing, we identified 3 of 27 students selected for testing who had taken online courses did not have documentation of the student?s academic attendance. Questioned costs: None Context: The College did not retain documentation supporting the student?s academic attendance as defined by US Department of Education. The three exceptions represented $2,590 out of a total $118,637 tested. The expenditures of those students who had taken online classes for the year ended June 30, 2021 were $2,686,888. Cause: Lack of oversight by management to verify students were participating in classes and were not actual withdraws. Effect: Lack of oversight of distance education courses could lead to fraudulent use of federal aid for purposes of a student not actually attending classes. Repeat Finding: No Recommendation: We recommend the College review and strengthen its procedures for documenting a student?s academic attendance including that the activity is academic or academically related and the student?s attendance at the activity. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 003 Federal agency: U.S. Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: Various Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to National Students Loan Data System (NSLDS) through an enrollment roster file. The school is required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. At a minimum, schools are required to certify enrollment at least every 60 days. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our testing, we identified the following: - Related to 6 out of 40 students tested, the Enrollment Effective Date per Institution's Records and Enrollment Effect Date per NSLDS did not match. - Related to 2 out of 40 students tested, the Program Enrollment Status per NSLDS did not match the Enrollment Effective Date per NSLDS. - Related to 25 out of 40 students tested, the Student Program Begin Date per NSLDS did not match the Institution's Records. - Related to 19 out of 40 students tested, the students were not certified every 60 days. - Related to 21 out of 40 students, the students were not reported within 30 days of the change, or the next reporting cycle if within 60 days. Questioned costs: None Context: The College's reporting to NSLDS is not supported by enrollment records. The College investigated the issues related to the Enrollment Effective Date and program Enrollment Status and were not able to identify why the dates did not match. Related to the Program Begin Date, the dates are between terms during period of enrollment. The dates used are when the student registered for classes. The 19 students who were not certified every 60 days were certified on March 25, 2021 then on June 1, 2021. Lastly, the students were not reported within the reporting cycle due to issues in the report submitted to National Student Clearinghouse (NSC). Cause: The College doesn?t have procedures in place to accurately report elements required under the enrollment reporting requirements. Effect: The College did not comply with US Department of Education (ED) regulations by accurately reporting student enrollment information. Repeat Finding: No Recommendation: We recommend reviewing the reporting process to ensure reports are submitted and accepted timely and the dates reported are accurate. Views of responsible officials: There is no disagreement with the audit finding.

2021 ? 004 Federal agency: U.S. Department of Education Federal program title: COVID-19 Higher Education Emergency Relief Fund ? Student and Institutional Portion Assistance Listing Number: 84.425E & F Award Period: July 01, 2020 - June 30, 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations and program compliance requirements. Condition: During our testing of student funds and institutional funds, we identified 23 out of 60 student funds selected for testing were not approved in accordance with the College?s policies and procedures. Questioned costs: None Context: A control system to prevent and detect errors in the student and institutional disbursement list was not operating effectively. The 23 exceptions represented $13,672 out of total student funds tested of $63,017. Total HEERF expenditures to students for the year ended June 30, 2021 was $5,053,374. Cause: During the testing, students either received HEERF funds via check or direct deposit or the funds were applied to the students account with the College. The student?s preference was indicated on the application they completed. For those students who received HEERF funds to their account with the College, there was no documented review approving the student should be awarded the HEERF funds. Effect: Funds could be spent on ineligible purposes. Repeat Finding: No Recommendation: We recommend the College retain documentation of the review approving that the disbursement to students of the HEERF funds. Views of responsible officials: There is no disagreement with the audit finding.

2020 ? 001 Federal agency: U.S. Department of Education Federal program title: Coronavirus Aid, Relief, and Economic Security Act, Section 2 ? Higher Education Emergency Relief (HEERF) CFDA Number: 84.425 Award Period: July 01, 2019 - June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: There was one vendor paid over $25,000. During testing of the vendor, it was noted there was no documentation to ensure the vendor was not suspended or debarred at the time of purchase. In addition, there was no review of this vendor. Questioned costs: None Context: During our testing, CliftonLarsonAllen (CLA) noted there was no documentation to ensure the vendor was not suspended or debarred. It was noted the procedure to check the SAM.gov website was performed but no documentation of this was retained. In addition, there was no documentation of review to ensure the vendor was not suspended or debarred. Cause: The control system to prevent payment to a suspended and barred vendor was not in place. Effect: The College could have paid a vendor who is suspended or barred at the time of payment. Repeat Finding: No Recommendation: CLA recommends documenting the vendor was checked on the SAM.gov website prior to payment. In addition, CLA recommends a supervisor to review the documentation prior to payment as a second review. Views of responsible officials: There is no disagreement with the audit finding.

GSA_MIGRATION

GSA_MIGRATION