Harford Community CollegeHigher Education

Federal agency: Department of Education Federal program title: Federal Pell Grant Program, Federal Direct Loan Program Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P221554 and P268K231554 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters (Nonmaterial Noncompliance) Criteria or specific requirement: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment and the Program-Level in addition to the Campus-Level. Included in this required reporting is an Enrollment status for each program which a student is enrolled. The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS). Regulations require the status include an accurate effective date. Condition: The enrollment status of graduation for two students was not updated to NSLDS from the correct withdrawn status. Questioned costs: None Context: This condition occurred for 2 out of 22 students selected for testing. Cause: These two students stop attending in the Fall 2022 semester. At that time, the two students were reported correctly to NSC and NSLDS with an enrollment status as withdrawn from institution with the end of fall semester date. Subsequently, both students graduated in Spring 2023. As part of the College’s normal end-of-term business practice, the College supplies a graduation file to NSC. The graduation file lists all students who graduated for the term. The graduation file for Spring 2023 supplied to NSC properly included these two students. Unfortunately, NSC does not automatically update a student’s status if the student has been away from the College for more than 120 days. These two students fell within that window since their last day of attendance was during the Fall 2022 semester. When NSC uploaded the spring graduation file to NSLDS, these two students were marked as grad not applied due to both students being in a withdrawn status for over 120 days. Moving forward, the College will add an additional step to the reporting business process and manually update students who have graduated, but have not been enrolled for more than 120 days. Effect: Enrollment status was not updated properly to NSLDS. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses and enrollment information are correctly and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a nonfederal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction greater than $25,000 is not debarred, suspended, or otherwise excluded. Condition: The College did not have a policy in place to verify that a vendor had not been suspended or debarred, at the time the College entered into certain transactions greater than $25,000 with vendors. This policy was updated late in the year ended June 30, 2022, and the vendors were reviewed at that time. Questioned costs: None Context: This condition occurred for 5 of 5 vendors selected for testing. Cause: The general Terms & Conditions attached to College Purchase Orders were designed to protect the College when entering into agreements with vendors. Unfortunately, these Terms & Conditions were not updated to include the Uniform Guidance criteria pertaining to transactions with debarred, suspended or otherwise excluded vendors until late in the year ended June 30, 2022. Effect: The College could enter a covered transaction with a vendor who is suspended or debarred and not be in compliance with Uniform Guidance requirements. Repeat Finding: Yes Recommendation: We recommend the College continue to follow its policy which dictates how the College will ensure suspension and debarment procedures are followed for any aggregate disbursements with vendors greater than $25,000. This process should occur prior to entering into the transaction. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated May 13, 2021, institutions are required to submit (in a time and manner required by the Secretary) reports to the Secretary describing the use of funds distributed from the HEERF. Condition: The quarterly HEERF report for the period October 1, 2021 to December 31, 2021, understated the amount of student aid grants from HEERF III funds by $80,165. Questioned costs: None Context: This condition occurred for 1 of 2 quarterly student reports selected for testing. Cause: The reporting requirements of HEERF were extensive and came from various sources within the College. Unfortunately, due to the multiple data summations involved in the quarterly reporting, an amount was mis-reported. Effect: Information reported in the quarterly HEERF report for the period October 1, 2021 to December 31, 2021, was incorrect. Repeat Finding: No Recommendation: We recommend the College review its processes for collecting and submitting grant reports to ensure all required elements are reported correctly. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a nonfederal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The College could not produce documentation to show that they verified that a vendor had not been suspended or debarred. Questioned costs: None Context: This condition occurred for 1 of 5 vendors selected for testing. Cause: The general Terms & Conditions attached to College Purchase Orders were designed to protect the College when entering into agreements with vendors. Unfortunately, these Terms & Conditions were not updated to include the Uniform Guidance criteria pertaining to transactions with debarred, suspended or otherwise excluded vendors. Effect: The College could enter a covered transaction with a vendor who is suspended or debarred and not be in compliance with Uniform Guidance requirements. Repeat Finding: No Recommendation: We recommend the College implement a policy which dictates how the College will ensure suspension and debarment procedures are followed for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: Federal regulations require institutions to submit an annual report to collect information about how the school used its CARES Act Section 18004(a)(1), (a)(2) and (a)(3) HEERF I funds. Condition: The number of students reported as eligible for HEERF I grants in the annual report did not agree to supporting documentation. Questioned costs: None Context: The College was required to submit an annual HEERF I report for the period April 20, 2020 through December 31, 2021. This condition occurred for one of the reported amounts on the annual report. Cause: The annual reporting requirements of HEERF I were extensive and came from various sources within the College. Unfortunately, due to the multiple data summations involved in the HEERF I Annual Report an amount was mis-reported. Effect: Information provided in the HEERF I annual report was incorrect. Repeat Finding: No Recommendation: We recommend the College review its processes for compiling grant reports to ensure proper amounts being reported. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: Per the National Student Loan Data System (NSLDS) Enrollment Reporting Guide, schools are required to report enrollment at both the Program-Level and the Campus-Level. Included in this required reporting is an Enrollment Effective Date for each program which a student is enrolled. The Enrollment Status Effective Date is defined as ?the date that the current enrollment status reported for a student was first effective.? Condition: Certain students are not reported with the correct enrollment effective dates within the Program-Level enrollment reporting in NSLDS. Questioned costs: None Context: This condition occurred for 12 out of 60 students selected for testing as follows: ? For 10 students, the Program-Level enrollment effective date incorrectly reported the semester census date instead of the semester start date. ? For one student, the Campus-Level effective date was reported as the start of the Spring semester instead of the start of the Winter term as reported in the Program-Level enrollment report. ? For one student, the Program-Level enrollment did not reflect the correct re-enrollment date at the start of the Spring semester. Cause: The interface between Banner, National Student Clearinghouse (NSC) and NSLDS for reporting enrollment effective dates at the Program-Level for students who have changed enrollment status from fall to spring is currently pulling from an incorrect data point. Effect: Enrollment effective dates are not reported accurately at the Program-Level reporting in NSLDS. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? enrollment effective dates are accurately reported within the Program-Level enrollment reporting to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS). Regulations require the status include an accurate effective date. When a student withdraws during a term (or, in a nonterm program, during a payment period), the effective date for the withdrawn (W) status is the withdrawal date used by the institution in accordance with 34 CFR 668.22(c)- Withdrawal date for a student who withdraws from an institution that is not required to take attendance. Condition: Students who withdraw unofficially from the College are not reported with an accurate effective withdraw date to the NSLDS. The College reports the effective date based on the date that the College determines that the student withdrew, generally the end of the semester. Questioned costs: None Context: This condition occurred for 26 out of 60 students selected for testing. Cause: The effective withdraw date is reported differently between the Financial Aid Office and the Registrar?s Office. The enrollment status file needs to use the R2T4 Form withdraw date (last date of attendance) calculated by the Financial Aid Office, not the date of determination as currently used by the Registrar?s Office. Effect: Effective withdrawal dates are not reported accurately to NSLDS. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses and enrollment information are accurately reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: Students who withdraw unofficially from the College are not reported timely to NSLDS. When a student withdraws from the semester and does not notify the College, the College is not made aware until the end of the semester. It is the College?s policy to report these withdraws at the beginning of the following semester, beyond 60 days from the date that the College determined the student has withdrawn. Questioned costs: None Context: This condition occurred for 9 out of 60 students selected for testing. Cause: The effective withdraw date is reported differently between the Financial Aid Office and the Registrar?s Office for R2T4 students. Due to the difference in processes, student enrollment statuses were ?assumed? to be continuing to the next semester and were reported at the first enrollment file for the following semester with an effective withdrawal date as the last date of the past semester. Effect: Student enrollment status was not reported timely to NSLDS. Repeat Finding: Yes, reported as finding 2020-002. Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses and enrollment information are timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. NSLDS requests a roster file for enrollment reporting from NSC, and it is the College?s responsibility to add certain students to the roster response if these students are not requested by NSLDS. Students to be added include any student who received Pell or other Title IV aid at the College but do not appear on the roster from NSLDS (NSLDS Enrollment Reporting Guide chapter 3.2). Condition: Students receiving Title IV funds were not reported to the NSLDS during the award period and as a result, enrollment status changes also were not reported to the NSLDS within the required timeframe. Questioned costs: None Context: This condition occurred for three out of 40 students selected for testing. Cause: The College uses the National Student Clearinghouse (NSC) as a third-party servicer to submit enrollment updates to NSLDS. NSLDS requests roster updates from NSC for a specific roster of students that NSLDS has on file. However, it is the College?s responsibility to update their roster file for any students who received Title IV aid but do not appear on the roster. The College did not update the roster for these 3 students and therefore their status changes were never communicated to NSLDS. Effect: Student enrollment status was not correctly reported to NSLDS. Repeat Finding: No Recommendation: We recommend the College review its reporting procedures to ensure that students? statuses and enrollment information are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

Criteria or specific requirement: Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act allows the recipient to use up to 50% of the funds received "to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus?" Other allowable expenditures under the Institutional Portion include additional emergency grants made to students (in accordance with the requirements of the Student Portion). Disbursements made under the Student Portion are required to be made directly to students. According to the Recipient?s Funding Certification and Agreement for the Institutional Portion of the HEERF, the recipient retains discretion in determining how to allocate and use the funds provided, provided that funds will be spent only on those costs for which recipient has a reasoned basis for concluding such costs have a clear nexus to significant changes to the delivery of instruction due to the coronavirus. It is permissible for recipient to use the funds for Recipient?s Institutional Costs to reimburse itself for costs related to refunds made to students for housing, food, or other services that Recipient could no longer provide, or for hardware, software, or internet connectivity that Recipient may have purchased on behalf of students or provided to students. Condition: The College reimbursed itself for costs related to refunds made to CET students that were not supported by payments to the student. Questioned costs: $5,554 (The known questioned costs of $5,554 produced an error rate that, when projected to the population, resulted in material likely questioned costs). Context: 48 refunds to CET students were selected for testing. The testing resulted in 16 individual refund issues. For 11 of the students selected for testing, the student received a senior citizen or employee tuition waiver. The student never paid tuition for the class and no tuition was refunded, therefore, the tuition refund should not have been submitted for reimbursement to HEERF. For three of the students selected for testing, the students? tuitions had yet to be refunded, and therefore, were not eligible for reimbursement from HEERF. For one student selected for testing, the student was properly refunded for section I of the cancelled class, but sections I and II were submitted for reimbursement from HEERF. Finally, one of the students selected for testing, properly did not receive a refund because the class was not cancelled. Unfortunately, the class was submitted for reimbursement to HEERF. HARFORD COMMUNITY COLLEGE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUED) YEAR ENDED JUNE 30, 2020 (14) Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Cause: Class rosters were used to justify and substantiate refunds for each CET course; however, the College did not take into consideration those students who had been previously approved and received tuition waivers. The College also employs a manual process for registering and de-registering CET students. The manual process caused an oversight of refunds due to three CET students. Additionally, the manual process for CET course registrations led to a duplicated drawn down of a two-part course, and also a draw for a course that ultimately was not cancelled. Effect: The College has drawn down from the Fund for ineligible amounts. Repeat Finding: No Recommendation: We recommend the College revise procedures for identifying refunds made to CET students ensuring that only refunds actually disbursed to students are charged to the grant. Views of responsible officials: There is no disagreement with the audit finding. Refer to the College?s response on attached letterhead.

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