EIN: 770070782
UEI: Y9KAMYJ8Z6C5
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 26, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by August 26, 2026 (3 days from today).
What is a management decision? →Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Furthermore, when a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Material Weakness in Internal Control over Compliance – We identified that 24 students of 60 tested had incorrect effective withdrawal dates reported to NSLDS. These dates were incorrectly reporting the student’s enrollment date to NSLDS, rather than their actual withdrawal date, due to a coding error in the District’s student information system. Additionally, we noted one student who received a Direct Loan whose withdrawal status was not certified in NSLDS within the required 60-day period following their withdrawal, due to this coding error. Questioned Costs None noted. Context We tested a non-statistical sample of 60 student status changes of more than 250 identified during the 2025 fiscal year. Effect Failure to report accurate and timely withdrawal information to NSLDS can result in: Improper loan servicing timelines, Incorrect calculation of grace periods and repayment start dates, Potential noncompliance with Title IV program requirements, and Risk of financial exposure to the institution and borrowers. Repeat Finding (Yes or No) No. Cause The condition resulted from a system configuration error in the District’s student information system. Specifically, the system was defaulting the withdrawal effective date to the student’s enrollment date, regardless of the actual withdrawal or last date of academic activity. This error went undetected during the reporting process. Recommendation The District should implement controls to ensure effective dates of enrollment status changes are accurately captured and reported to NSLDS. Because this is a partially automated process through the District’s information systems, we recommend implementation of system improvements to ensure that the correct effective date, rather than the process or run date, is reported.
Show full finding ▾Hide full finding ▴Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Furthermore, when a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition Material Weakness in Internal Control over Compliance – We identified that 24 students of 60 tested had incorrect effective withdrawal dates reported to NSLDS. These dates were incorrectly reporting the student’s enrollment date to NSLDS, rather than their actual withdrawal date, due to a coding error in the District’s student information system. Additionally, we noted one student who received a Direct Loan whose withdrawal status was not certified in NSLDS within the required 60-day period following their withdrawal, due to this coding error. Questioned Costs None noted. Context We tested a non-statistical sample of 60 student status changes of more than 250 identified during the 2025 fiscal year. Effect Failure to report accurate and timely withdrawal information to NSLDS can result in: Improper loan servicing timelines, Incorrect calculation of grace periods and repayment start dates, Potential noncompliance with Title IV program requirements, and Risk of financial exposure to the institution and borrowers. Repeat Finding (Yes or No) No. Cause The condition resulted from a system configuration error in the District’s student information system. Specifically, the system was defaulting the withdrawal effective date to the student’s enrollment date, regardless of the actual withdrawal or last date of academic activity. This error went undetected during the reporting process. Recommendation The District should implement controls to ensure effective dates of enrollment status changes are accurately captured and reported to NSLDS. Because this is a partially automated process through the District’s information systems, we recommend implementation of system improvements to ensure that the correct effective date, rather than the process or run date, is reported.
The District has identified the issue and confirmed that enrollment records are now populating with the correct withdrawal dates. Moving forward, we will collaborate with Financial Aid and IT to implement a validation process. As part of this process, a sample of 20 students will be tested each reporting cycle to verify that dates reported to the National Student Clearinghouse (NSC) are accurately reflected in the National Student Loan Data System (NSLDS). To ensure continued compliance, the District will establish a new Enrollment Reporting Workgroup that will meet once per semester, following the submission of the second NSC report. This workgroup will review results of the sample testing, monitor reporting accuracy, and address any discrepancies promptly.
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
Allowable Costs & Activities Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department ofthe Treasury Pass-Through Entity: California Community Colleges Chancellor's Office Criteria or Specific Requirements The Uniform Guidance Cost Principals described in 31 CFR Part 35, Subpart A, established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) to support governments in their response to and recovery from the COVID-19 public health emergency. As outlined in the Final Rule set forth by the U.S. Department of the Treasury, to identify eligible uses of funds, recipients should (1) identify a COVID-19 public health or economic impact on an individual or class (i.e., a group) and (2) design a program that responds to that impact. As a recipient of CSLFRF funding, the California Community Colleges Chancellor’s Office (CCCCO) utilized the funding to provide emergency financial assistance grants to low-income students, enrolled at the California community colleges, who had been disproportionally impacted by the COVID-19 public health emergency. The CCCCO established the following eligibility criteria for students to receive CSLFRF grants: • U.S. citizen or eligible non-citizen • Current enrollment in credit or noncredit courses at a California community college • Demonstrate an emergency financial aid need • Qualify as low-income by meeting the requirements to receive a California College Promise Grant (CCPG} or is projected to receive a CCPG for the upcoming term Condition Significant Deficiency – The District disbursed CSLFRF grants to 2 ineligible students out of the 23 students tested. Questioned Costs During our testing, we identified that the District disbursed $6,000 in CSLFRF to 2 ineligible students out of the 23 students tested. Context The District disbursed CSLFRF grants to 115 students during the fiscal year totaling $336,724 in aid. Effect Without proper monitoring of the eligibility requirements set forth by the pass-through entity, the District is at risk of noncompliance with the above referenced criteria. Cause The District did not comply with the most up-to-date student eligibility requirements set forth by the California Community College Chancellor’s Office. Recommendation It is recommended that District establish effective controls and procedures to ensure that funds are only being distributed to those who are eligible to receive CSFRF student aid.
Show full finding ▾Hide full finding ▴Allowable Costs & Activities Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: U.S. Department ofthe Treasury Pass-Through Entity: California Community Colleges Chancellor's Office Criteria or Specific Requirements The Uniform Guidance Cost Principals described in 31 CFR Part 35, Subpart A, established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) to support governments in their response to and recovery from the COVID-19 public health emergency. As outlined in the Final Rule set forth by the U.S. Department of the Treasury, to identify eligible uses of funds, recipients should (1) identify a COVID-19 public health or economic impact on an individual or class (i.e., a group) and (2) design a program that responds to that impact. As a recipient of CSLFRF funding, the California Community Colleges Chancellor’s Office (CCCCO) utilized the funding to provide emergency financial assistance grants to low-income students, enrolled at the California community colleges, who had been disproportionally impacted by the COVID-19 public health emergency. The CCCCO established the following eligibility criteria for students to receive CSLFRF grants: • U.S. citizen or eligible non-citizen • Current enrollment in credit or noncredit courses at a California community college • Demonstrate an emergency financial aid need • Qualify as low-income by meeting the requirements to receive a California College Promise Grant (CCPG} or is projected to receive a CCPG for the upcoming term Condition Significant Deficiency – The District disbursed CSLFRF grants to 2 ineligible students out of the 23 students tested. Questioned Costs During our testing, we identified that the District disbursed $6,000 in CSLFRF to 2 ineligible students out of the 23 students tested. Context The District disbursed CSLFRF grants to 115 students during the fiscal year totaling $336,724 in aid. Effect Without proper monitoring of the eligibility requirements set forth by the pass-through entity, the District is at risk of noncompliance with the above referenced criteria. Cause The District did not comply with the most up-to-date student eligibility requirements set forth by the California Community College Chancellor’s Office. Recommendation It is recommended that District establish effective controls and procedures to ensure that funds are only being distributed to those who are eligible to receive CSFRF student aid.
Response Two different sets of guidelines were issued for the Coronavirus State and Local Fiscal Recovery Funds. The first set of guidelines were issued in March 2021 (Attachment A). These first set of guidelines allowed undocumented students to receive the award #4 (Attachment A). These are the guidelines that were used to award students monies from this fund. During the audit, it was noted that SBCC incorrectly awarded undocumented students with monies from the Coronavirus State and Local Fiscal Recovery Funds. SBCC was not aware at the time of awarding these monies that a second guidance memo had been issued by the Community Colleges of California Chancellor’s Office (CCCCO) on Friday, January 21,2022 (Attachment B). The updated memo clearly stated that undocumented students were no longer eligible for these funds. SBCC had not updated its protocols to match the second memo due to staffing issues within th e financial aid office. Specifically, the manager of the Financial Aid Office was out on disability leave from January 26 through September 28, 2022. However, no funds were awarded during this absence. Within the new guidance, a new process stated how to corrects awards given to candidates originally eligible (undocumented students) under the first memo, but no longer eligible under the second memo. Per the second memo, any incorrectly awarded funds under the first policy were to be replaced with other funds that undocumented students are eligible to receive. Corrective Action To correct the incorrect awarding of funds to ineligible candidates, SBCC cancelled the awards to now ineligible recipients of Early Action Fund (EMASS/SRFR) and replace d them with awards from AB19 monies, which were rolled over from 22-23. SBCC also used monies from remaining HEERF/CARES funds, which allowed for awards to undocumented students. In total, SBCC corrected 16 awards totaling $48,000. SBCC’s records now reflect that no undocumented students received Coronavirus State and Local Fiscal Recovery Funds. Going forward, SBCC is now awarding under the correct guidelines. No further awards have been made to undocumented students. The fund is winding down and will be spent in full by the end of the 23-24 fiscal year.
FAC accepted this audit on January 5, 2022 — management decision was due July 5, 2022.
2021-001 Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student's control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency in Internal Control over Compliance ? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 9 of 40 Return to Title IV calculations were incorrectly calculated. ? 11 of 40 Return to Title IV calculations were performed outside of the allowable timeframe. Questioned Costs Questioned costs include $2,217 of funds that were not returned to U.S (ED). Context The District did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. Effect Without proper monitoring of accuracy and student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
Show full finding ▾Hide full finding ▴2021-001 Special Test and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. 34 CFR section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student's control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency in Internal Control over Compliance ? During testing over Return to Title IV requirements, the following deficiencies were noted: ? 9 of 40 Return to Title IV calculations were incorrectly calculated. ? 11 of 40 Return to Title IV calculations were performed outside of the allowable timeframe. Questioned Costs Questioned costs include $2,217 of funds that were not returned to U.S (ED). Context The District did not perform R2T4 calculations for students under the Pell Grant and Direct Loan Programs timely or accurately. Effect Without proper monitoring of accuracy and student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were performed accurately and returned in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should implement procedures to ensure that the student withdrawal calculations are performed accurately and returned within 30 days from the end of the academic period.
The Financial Aid Office spoke with the District?s auditors to understand the details of the errors noted above. After an internal investigation that did not yield success, we hired an outside consultant with expertise in Banner. It was discovered that a defect in Banner in Spring 2021 created a set of circumstances that we believe uniquely impacted Santa Barbara City College. The defect caused the automated Banner system to believe that any financial aid, not just ?accepted? financial aid, should be included in the R2T4 calculation. Santa Barbara City College awards federal student loans in an automated packaging system. Due to the Spring 2021 defect, Banner began to calculate all ?offered? aid as ?received? aid, thus adding the ?unaccepted? but offered federal student loans into the R2T4 calculation. This defect impacted only Spring 2021, Summer 2021 and Fall 2021 (until November 29, 2021). To correct this defect, we performed the following steps: ? We retroactively fixed all defective calculations for each semester noted. ? We created a viable workaround for the remainder of the 2021-22 award year (manually canceling all ?offered? loans prior to conducting the R2T4 calculation). ? We have created a permanent automated fix and will implement it into the 2022-23 academic year at the annual system rollout. An update to our R2T4 policies and procedures has been made to address the second bullet point. In the past, we have tried to verify the last date of attendance with other administrative offices or directly with the student, to ensure that all ?earned? aid and the correct last date of attendance was used. Beginning with the 2021-2022 award year, the Financial Aid Office will rely on the date as published in the student record in the Admissions and Records Office.
2021-002 Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 6 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 30 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? 2 of 60 students did not have program enrollment information reported to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 3,299 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
Show full finding ▾Hide full finding ▴2021-002 Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 ? Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions? Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following deficiencies were noted: ? 6 of 60 student effective dates were not accurately reported as NSLDS (dates of change do not agree to effective dates). ? 30 of 60 student enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). ? 2 of 60 students did not have program enrollment information reported to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 3,299 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Repeat Finding (Yes or No) No Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.
The Office of Admissions and Records will be working with the NSC to review our current reporting timelines and process. In addition, the Admissions Office will review reports with IT staff and the Office of Institutional Assessment, Research and Planning for accuracy prior to submitting reports to the NSC portal to confirm the current enrollment status of impacted students.
2021-003 Reporting - Common Origination and Disbursement (COD) Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063 and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report studentpayment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency in Internal Control over Compliance - The process dates reported in the COD files for student disbursements were more than 15 calendar days after the disbursement dates reported in the COD files and in the District's financial records for the Fall 2020 and Spring 2021 semesters. 6 of the 60 student disbursements tested were reported to COD in excess of 15 days after disbursement. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District processed and reported approximately $11,493,796 in Pell grants during the year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District did not report student files to COD in a timely manner to ensure compliance within the 15 calendar day timeframe required. Repeat Finding (Yes or No) No Recommendation The District should review their polices and control procedures in place over COD reporting to ensure timely reporting within the 15-calendar day requirement.
Show full finding ▾Hide full finding ▴2021-003 Reporting - Common Origination and Disbursement (COD) Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063 and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report studentpayment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency in Internal Control over Compliance - The process dates reported in the COD files for student disbursements were more than 15 calendar days after the disbursement dates reported in the COD files and in the District's financial records for the Fall 2020 and Spring 2021 semesters. 6 of the 60 student disbursements tested were reported to COD in excess of 15 days after disbursement. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District processed and reported approximately $11,493,796 in Pell grants during the year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District did not report student files to COD in a timely manner to ensure compliance within the 15 calendar day timeframe required. Repeat Finding (Yes or No) No Recommendation The District should review their polices and control procedures in place over COD reporting to ensure timely reporting within the 15-calendar day requirement.
The Financial Aid Office has reviewed this finding to understand the nature and cause of the error noted above. The Financial Aid Office has a written calendar where all COD reporting is noted and executed on a timely basis. It is our belief that this one-time error is based on the intricacies of working in a COVID/Virtual environment (the finding is from August 2020). We do not believe this finding will reoccur.
2021-004 Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 10 days after each calendar quarter-end. Condition Significant Deficiency in Internal Control over Compliance - During our testing over reporting for the Student Aid Portion, we noted that the report required to be publicly each quarter did not contain all the required elements. The estimated number of students eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act, was not disclosed and updated for each reporting quarter. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District?s quarterly reports did not contain all the required data elements. Effect The District is not in compliance with Federal reporting requirements described in the OMB Compliance Supplement. Cause The District did not review their website to ensure that all required reporting elements were present and updated each quarter. Repeat Finding (Yes or No) No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
Show full finding ▾Hide full finding ▴2021-004 Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 10 days after each calendar quarter-end. Condition Significant Deficiency in Internal Control over Compliance - During our testing over reporting for the Student Aid Portion, we noted that the report required to be publicly each quarter did not contain all the required elements. The estimated number of students eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act, was not disclosed and updated for each reporting quarter. Questioned Costs There are no questioned costs associated with the noncompliance. Context The District?s quarterly reports did not contain all the required data elements. Effect The District is not in compliance with Federal reporting requirements described in the OMB Compliance Supplement. Cause The District did not review their website to ensure that all required reporting elements were present and updated each quarter. Repeat Finding (Yes or No) No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
The HEERF I, II, and III funding?s involve coordination of reporting related to student and institutional portions. Specifically, on an annual basis, this information must be compiled together by Fiscal Services and Financial Aid, using a single set of login credentials. On a quarterly basis, the institutional and student portions must be reported per the requirements described in the OMB Compliance. Unlike the institutional portion, there is not a specific quarterly, report form provided for the student portion. Instead, the District must identify all the required reporting elements and report them on its website. Due to lack of a more structured reporting format, the District did not report all elements on a quarterly basis. As a corrective action plan, the District will formalize a reporting structure that captures all required reporting elements. This new format will be applied to previously reported information to bring all reporting into compliance. Additionally, Fiscal Services and Financial Aid will work together to submit/post quarterly and annual reports. This new process will allow for the calendarization of due dates, as well as a review process to ensure completeness of reporting.
FAC accepted this audit on March 18, 2021 — management decision was due September 18, 2021.
2020-001 Reporting Direct Programs ? Department of Education CFDA# 84.425E COVID-19 - Higher Education Emergency Relief Funds ? Student Aid Porttion Reporting Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award allocation date, and update that information every 45 days thereafter. Condition During our testing over reporting for the student aid portion, we noted that the report required to be publicly available 30 days following the award becoming available was late by 18 days and therefore, the District did not meet the timeliness requirement. Cause The District believed that the timing of the 30 day reporting requirement was based on when the funds were first disbursed to students. Effect The District?s 30 day report was uploaded to their website 18 days late. Questioned Costs None reported Context/Sampling The District was required to report student grant metrics and other data within 30 days of their award allocation date. The report was reviewed for compliance and determined that it was not submitted in a timely manner. Repeat Finding from Prior Year No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
Show full finding ▾Hide full finding ▴2020-001 Reporting Direct Programs ? Department of Education CFDA# 84.425E COVID-19 - Higher Education Emergency Relief Funds ? Student Aid Porttion Reporting Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award allocation date, and update that information every 45 days thereafter. Condition During our testing over reporting for the student aid portion, we noted that the report required to be publicly available 30 days following the award becoming available was late by 18 days and therefore, the District did not meet the timeliness requirement. Cause The District believed that the timing of the 30 day reporting requirement was based on when the funds were first disbursed to students. Effect The District?s 30 day report was uploaded to their website 18 days late. Questioned Costs None reported Context/Sampling The District was required to report student grant metrics and other data within 30 days of their award allocation date. The report was reviewed for compliance and determined that it was not submitted in a timely manner. Repeat Finding from Prior Year No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.
View of Responsible Officials and Corrective Action Plan The District staff misinterpreted when the 30-day timeline began for having the report available publicly. Staff understood the reporting date to be 30 days from drawing down the funds, i.e. When the District took possession of the funds, not 30 days from when the award became available. District staff now understands this was a misinterpretation of the deadline for posting the report and will work to meet the 30-day deadline in the future.
FAC accepted this audit on December 8, 2016 — management decision was due June 8, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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