Alamo Community College DistrictHigher Education

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: September 1, 2024 – August 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The U.S. Department of Education offers financial aid to students under two programs: 1. Pell Grant program which provides grants to eligible students enrolled in eligible undergraduate programs and certain post-baccalaureate teacher certificate programs and 2. FSEOG program which provides grants to eligible undergraduate students with priority given to Pell recipients who have the lowest expected family contributions. Condition: The Pell Grant Program has maximum and minimum Pell grant awards established by statute and should be awarded based on the student's needs. During our testing, we noted that one of the sixty students tested was over awarded Pell funds. Questioned Costs: $1,849 Context: A system defect impacted Pell Grant disbursements, prompting the District to disable standard attending hours functionality. Attending hours were then locked in February for the Spring term. Subsequent enrollment changes requiring manual Pell Grant adjustments were missed due to human oversight, resulting in an over award of $1,849. Cause: The District's internal control process was not able to detect the over awarding of the Pell amounts. Effect: One student was over awarded $1,849 Repeat Finding: No Recommendation: We recommend the District evaluate the student’s status each semester. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: September 1, 2024 – August 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: We noted that one of the sixty students tested was not calculated for an R2T4 in the current year when they should have been. Questioned Costs: $3,199 Context: The student withdrew from the District mobile app, bypassing required advisor approval. This prevented the R2T4 workflow from recognizing the withdrawal, and the R2T4 calculation was delayed until identified. Cause: The District did not evaluate the student for R2T4. Effect: One of the students were not calculated. Repeat Finding: No Recommendation: We recommend the District should implement a comprehensive review process for R2T4 calculations and financial aid withdrawal listings to ensure all student withdrawals are accurately identified and processed in a timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Award Period: September 1, 2022 to August 31, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). In addition, per Uniform Guidance 2 CFR 200.303, 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: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: None Context: During our review of the GLBA reports for Alamo Community College District, we noted one of the eight required GLBA safeguards was missing from the written information security plan (District’s Enterprise Data Governance Standard), and there was no review of the plan. Cause: The Enterprise Data Governance Standard did not include one of the required GLBA safeguards. Effect: The District is not in full compliance with GLBA. Repeat Finding: No Recommendation: We recommend that the District review the updated GLBA requirements and ensure their Enterprise Data Governance Standard includes all required elements. Views of Responsible Officials: There is no disagreement with the audit finding. The District has a plan to correct the finding.

Federal Agency: Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425E Federal Award Identification Number and Year: N/A Award Period: September 1, 2022 to August 31, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR Section 200.407, institutions distributing HEERF funding are required to ensure that students meet the eligibility requirements of the program while following established policies and procedures. In addition, per Uniform Guidance 2 CFR 200.303, 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 expenditures of HEERF funding, we identified certain internal control policies of the District were not followed. Questioned Costs: None Context: During our testing of the HEERF student expenditures, we identified certain instances where internal control policies of the District were not followed at Northwest Vista College. Cause: The District in certain instances did not follow the internal control policies implemented around the awarding of HEERF student funds. Effect: There were certain instances where HEERF funds were disbursed that did not follow the District’s internal control policies. Repeat Finding: No Recommendation: We recommend that the District review their internal processes and ensure all internal control policies are followed. Views of Responsible Officials: There is no disagreement with the audit finding. The District has a plan to correct the finding.

Finding 2022-001: Enrollment Reporting Submissions for Graduates U.S. Department of Education Student Financial Assistance Cluster Program Name(s): Federal Pell Grant Program, ALN 84.063 and Federal Direct Student Loans, ALN 84.268 Award Numbers: P063P216822 (Palo Alto College); P063P215081, P268K225081 (San Antonio College) Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: According to the Office of Management and Budget (OMB) 2022 Compliance Supplement, institutions are required to report enrollment status information under the Pell Grant and the Direct Student Loan programs via the National Student Loan Data System (NSLDS) in a timely and accurate manner. The Department of Education (ED) requires the enrollment information to be submitted at least every 60 days. Condition and Context: As part of our testing of the District?s compliance with enrollment reporting requirements, it was noted that for 4 students (all of whom were Pell Grant recipients and 1 was also a Direct Loan recipient; students were attendees of Palo Alto College and San Antonio College) out of the total of 40 students sampled, the District did not ensure that the students? enrollment status of ?Graduated? was reported to NSLDS. The sample size to be tested was not determined using a statistical sampling approach. Cause: The submission of enrollment information is a systemic process in which a report is generated in Banner, the District?s ERP system; the District sends that information to the National Student Clearinghouse (NSC), who then submits it to the NSLDS. For students who have graduated, the District uses a free service from NSC called DegreeVerify, through which NSC reviews the students on the District?s ?Graduate? file to determine whether it can create a ?Graduated? enrollment record. An exceptions report is then created within NSC listing those students whose status could not be updated to ?graduated?. The District is then required to review the exceptions report and resend the list to NSC indicating that the student?s status does in fact need to be updated to ?Graduated.? The District did not review the exception reports for the current year, which resulted in the 4 students noted above not having their ?Graduated? status reported to NSLDS by NSC. Effect or Potential Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Complete and accurate reporting of students? enrollment information to NSLDS is critical, as this information is used to determine the subsidy status of certain loans and for other purposes. The lack of timely enrollment reporting could result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. See ?Condition? above for instances of noncompliance identified in the current period which were not identified as material noncompliance. Questioned Costs: There are no questioned costs. Repeat Finding: No Recommendation: We recommend that management implement a process to review the DegreeVerify exceptions report and indicate to NSC that student statuses need to be updated to ?Graduated.? This process should be performed with sufficient regularity to ensure that enrollment information reported to the NSLDS is complete and accurate. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan

Finding 2022-002: Accuracy of Periodic Grant Reporting U.S. Department of Education Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund, ALN 84.425 Award Numbers: P425F202774 and P425S210113 (Northeast Lakeview College) Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: According to the Office of Management and Budget (OMB) 2022 Compliance Supplement, the U.S. Department of Education (ED) requires institutions to publicly report certain information under Higher Education Emergency Relief Fund (HEERF) Subprogram E in one report and HEERF Subprograms F, J, and L in a second report. Each report is required to be accurate and posted each quarter to the institution?s website within specified timeframes. For the quarterly report under Subprograms F, J, and L, institutions are required to report total funds awarded and total amount expended under each Subprogram. Condition and Context: In our testing of the District?s quarterly reporting under HEERF, we noted that 1 out of a sample of 3 quarterly reports tested under Subprograms F, J, and L, which was posted by Northeast Lakeview College, did not include accurate amounts of total funds spent under each Subprogram. The sample size to be tested was not determined using a statistical sampling approach. Per the Office of Postsecondary Education (OPE) Reporting and Data Collection resource page, institutions are encouraged but not required to submit HEERF quarterly reports to the ED by emailing them to a designated ED email address. Therefore, it should be noted that the public is the primary audience for the HEERF quarterly reports. Cause: Although controls were in place at each college requiring review of the quarterly reports before being posted to their respective websites, this review process failed to detect the reports? omissions and inaccuracies. Effect or Potential Effect: The public can potentially be misinformed about total amount spent under each Subprogram due to the inaccurate information being reported on the colleges? websites. In addition, ED can potentially be misinformed about student data and use of funds under HEERF. See ?Condition? above for instances of noncompliance identified in the current period which were not identified as material noncompliance. Questioned Costs: There are no questioned costs. Repeat Finding: Yes, 2021-003 Recommendation: We recommend that management ensure that those charged with reviewing the quarterly reports have a clear understanding of the relevant reporting requirements in order to ensure that the reports are complete and accurate prior to being posted. In addition, the reports should be reconciled to the corresponding amounts in the District?s financial records prior to posting. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan

Finding 2021-002: Completeness of Enrollment Reporting Submissions U.S. Department of Education Student Financial Assistance Cluster Program Name(s): Federal Pell Grant Program, ALN 84.063 and Federal Direct Student Loans, ALN 84.268 Award Numbers: P063P206795 (Northwest Vista College); P063P205081 (San Antonio College); P063P206785 (St. Philip's College) Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: According to the Office of Management and Budget (OMB) 2021 Compliance Supplement, institutions are required to report enrollment status information under the Pell Grant and the Direct Student Loan programs via the National Student Loan Data System (NSLDS) in a timely and accurate manner. The Department of Education (ED) requires the enrollment information to be submitted at least every 60 days. Condition and Context: As part of our testing of the District's compliance with enrollment reporting requirements, it was noted that for 3 students (all of whom were Pell Grant recipients; students were attendees of Northwest Vista College, San Antonio College, and St. Philip's College) out of the total of 40 students sampled, the District did not report the students' enrollment status information via the NSLDS within 60 days after the enrollment status changed. The sample size to be tested was not determined using a statistical sampling approach. Cause: The submission of enrollment information is a systemic process in which a report is generated in Banner, the District's ERP system; the District sends that information to the National Student Clearinghouse (NSC), who then submits it to the NSLDS. The 3 students noted above took dual credit classes at the District while in high school and subsequently graduated from high school and enrolled in classes at the District. A student's participation in the dual credit program results in the inclusion of an attribute on the student's account in Banner which prevents them from being included in the enrollment information sent to NSC. This attribute is removed once the student graduates from high school, but there are instances in which the attribute reappears on the student's record without detection and subsequent removal of such by the District through the District's implemented internal controls, which results in inappropriate exclusion from enrollment reporting. Effect or Potential Effect: The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Complete and accurate reporting of students' enrollment information to NSLDS is critical, as this information is used to determine the subsidy status of certain loans and for other purposes. The lack of timely enrollment reporting could result in either a lack of timely repayments by the borrower or the student being inappropriately moved into loan repayment status. See "Condition" above for instances of noncompliance identified in the current period which were not identified as material noncompliance. Questioned Costs: There are no questioned costs. Repeat Finding: No Recommendation: We recommend that management implement a process to cross-reference enrollment reporting files to Pell Grant and Direct Loan disbursement details to ensure that there are not any Pell Grant or Direct Loan recipients improperly excluded from the enrollment reporting files. This process should be performed with sufficient regularity to ensure that enrollment information reported to the NSLDS is complete and accurate. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan

Finding 2021-003: Accuracy of Periodic Grant Reporting U.S. Department of Education Program Name: Higher Education Emergency Relief Fund, ALN 84.425 Award Numbers: P425E203619 (Northeast Lakeview College); P425F202498 (Northwest Vista College); P425F201748 and P425J200086 (St. Philip's College) Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: According to the Office of Management and Budget (OMB) 2021 Compliance Supplement, the U.S. Department of Education (ED) requires institutions to publicly report certain information under Higher Education Emergency Relief Fund (HEERF) Subprogram E in one report and HEERF Subprograms F, J, and L in a second report. Each report is required to be accurate and posted each quarter to the institution's website within specified timeframes. One of the required elements to be included in the quarterly report under Subprogram E is the method(s) used by the institution to determine which students receive emergency financial aid grants and how much they would receive. For the quarterly report under Subprograms F, J, and L, institutions are required to report total funds awarded and total amount expended under each Subprogram. Condition and Context: In our testing of the District's quarterly reporting under HEERF, we noted that 1 out of a sample of 3 quarterly reports tested under Subprogram E, which was posted by Northeast Lakeview College, was not posted on a timely basis and did not include the current method used by the institution to determine which students receive emergency financial aid grants and how much they would receive. In addition, 2 out of a sample of 3 quarterly reports tested under Subprograms F, J, and L, which were posted by Northwest Vista College and St. Philip's College, did not include accurate amounts of total funds awarded and/or total amount spent under each Subprogram. The sample size to be tested was not determined using a statistical sampling approach. Per the Office of Postsecondary Education (OPE) Reporting and Data Collection resource page, institutions are encouraged but not required to submit HEERF quarterly reports to the ED by emailing them to a designated ED email address. Therefore, it should be noted that the public is the primary audience for the HEERF quarterly reports. A separate Annual Performance Report is required to be submitted to ED by each college covering all Subprograms (E, F, J, and L). Cause: Although controls were in place at each college requiring review of the quarterly reports before being posted to their respective websites, this review process failed to detect the reports' omissions and inaccuracies. Effect or Potential Effect: The public can potentially be misinformed about (1) the colleges' method(s) used to determine which students emergency financial aid grants and how much they would receive, (2) total funds awarded under each Subprogram, and (3) total amount spent under each Subprogram due to the inaccurate information being reported on the colleges' websites. See "Condition" above for instances of noncompliance identified in the current period which were not identified as material noncompliance. Questioned Costs: There are no questioned costs. Repeat Finding: No Recommendation: We recommend that management ensure that those charged with reviewing the quarterly reports have a clear understanding of the relevant reporting requirements in order to ensure that the reports are complete and accurate prior to being posted. In addition, the reports should be reconciled to the corresponding amounts in the District's financial records prior to posting. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan