BLACKFEET COMMUNITY COLLEGE

Internal Controls and Compliance Special Test Return of Title IV Funds Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063 Award year and number: 2020 P063P194312 Criteria or Specific Requirement: Internal controls over Return of Title IV Funds should be properly designed to provide assurance of meeting compliance requirements and should operate effectively. In accordance with 34 CFR sections 668.22(a)(1) through (a)(5) "When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution's determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in this section and no additional disbursements may be made to the student for the payment period or period of enrollment. If the amount the student earned is greater than the amount disbursed, the difference between the amounts must be treated as a post-withdrawal disbursement". Condition: We noted a deficiency in the internal controls over Return of Title IV Funds resulting in noncompliance with unearned Title IV funds requirements. We determined the College did not follow its control procedures over the Return of Title IV Funds. We identified the following noncompliance: -The College calculated the unearned Title IV amount for one student who withdrew but did not process a payment for the unearned amount of Title IV funds, $453, to the Department of Education in a timely manner. Context: We performed a walkthrough over the student withdrawal procedure and Return of Title IV Funds calculation. We inquired with financial aid staff and business office staff. We examined student withdrawal documents and student accounts. We selected two, out of a total population of 12, student files who received a Pell disbursement and subsequently withdrew. Sample selection was not a statistical valid sample because sampling risk was not quantified. Questioned Costs: None Effect: The College did not comply with the Department of Education Return of Title IV Funds 45- daytime frame for return of funds. Cause: The College did not follow its procedure to ensure timely return of Title IV Funds to the Department of Education. Repeat: No Auditor's Recommendation: We recommend the College follow its procedures to ensure that the financial aid office and business office complete the Return of Title IV Funds calculation and disburse payment of unearned Title IV Funds to the Department of Education in a timely manner. View of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the finding.

The Financial Aid Director and Specialist will work with the applicable staff when a student has a total withdrawal (TWD) implemented when they have reported their intention to withdraw: 1. When receiving a copy of the TWD form, check the entry information on the student's date of total withdrawal as entered by the student services staff, 2. An R2T4 checklist will be used to ensure we have all we need to complete the R2T4 form 3. Checking the last date of last attendance reported by the instructor 4. Entering the drop date in the PowerFaids system by the date entered into Jenzabar by the registrar's office 5. Recalculating the award earned, if applicable, by the financial aid director 6. Email the completed R2T4 worksheet to student accounts 7. Return funds to the Department of Ed by adjusting the student's award in PowerFaids 8. Student accounts will readjust the change in funding for the student or BFCC 9. Returning any funds, if applicable, through GS by business office personnel 10. Send students a letter of their TWD, and its implications

Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063Award year and number: 2020 P063P194312 Criteria or Specific Requirement: Institutions are required to report enrollment information under the Pell grant 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 website. Condition: We noted a deficiency in the internal controls over Enrollment Reporting resulting in noncompliance with compliance requirements. The Financial Aid Office experienced employee turnover during the fiscal year resulting in a one-person office which contributed to inaccurate student status reporting. We noted four students who withdrew during the Fall 2019 semester were certified as full-time or half-time during January 2020.Context: We inquired with financial aid staff regarding procedures for Enrollment Reporting via the NSLDS. We selected 25 students, out of a total population of 243 students, to verify enrollment status reported during the year. Sample selection was not a statistical valid sample because sampling risk was not quantified. Questioned Costs: None Effect: The College did not comply with the Department of Education Enrollment Reporting requirements. Cause: The Financial Aid Office experienced turnover during the year. In addition, the College was operating from home during the majority of the fiscal year due to COVID-19. Repeat: No Auditor's Recommendation: We recommend the College implement procedures to ensure that the financial aid office has adequate staffing and reports student enrollment status accurately. View of Responsible Officials: Management agrees with the audit finding and has a plan in place to correct the finding.

As a corrective action we are all working in tandem to include the Registrar's Office, Financial Aid, Student Billing, and Student Accounts. There are checks and balances in place to verify each other's work. We have been identified as the Enrollment Services Department which has made a huge impact in the work we do as a team. This team effort will alleviate future occurrences. Further actions: 1. The former Financial Aid Specialist has been removed from the enrollment report, and that account has been deactivated, and BCC hired a new replacement. 2. The Registrar's Office will re-assume their role in completing the NSLDS Student Enrollment report. Returning the Registrar's Office's role will aid in entering this online repo rt, since the enrollment report includes: a. The student's enrollment date at BFCC b. The student's enrolled status c. When the students drop or add classes d. The student's declared major e. When student's change majors f. The CIP codes for the reported major g. The student's entry dates h. The student's re-entry dates i. The student's graduation dates 3. The Financial Aid and Registrar's Offices will work together in the future to get the report uploaded to the online NSLDS website using the Excel export and import file offered on the webpage. 4. The NSLDS Enrollment Report will be uploaded by the Registrar's Office to the National Student Clearinghouse, and the Financial Aid Office will be the backup for the report.

Federal program information: Funding agency: U.S. Department of Interior Title: Assistance to Tribally Controlled Community Colleges CFDA number: 15.027 Award year and number: 2019 Criteria or Specific Requirement: Pursuant to Title 25, U.S.C. 1808(a)(1), the Secretary shall grant for each academic year to each tribally controlled college or university having an application approved by the Secretary an amount equal to the product obtained by multiplying (A) the Indian student count at such college or university during the academic year preceding the academic year for which such funds are being made available. 25 U.S.C. 1801 (a)(7) defines "Indian student" as (A) a member of an Indian tribe or (B) a biological child of a member of an Indian tribe, living or deceased. Internal controls over compliance with Indian eligibility should be effectively designed and implemented to provide assurance of meeting compliance standards. Condition: While there were not any specific issues of non-compliance noted, we noted the following issues related to internal controls over the determination of eligibility of Indian students to be included in the Indian student count. ? One student file was missing the required admissions checklist. ? The admissions checklist in one student file was not completed. Context: We tested 40 out of 667 students for eligibility as Indian students. Our sample was not statistically valid because sampling risk was not quantified. Questioned Costs: None Effect: There is a chance the Indian student count could include ineligible individuals. The College may have an adverse affect on the funding amount based on inaccurate Indian student count information. Cause: The College did not follow the implemented procedures of completing the admissions checklist. Repeat: No Auditor's Recommendation: We recommend the College implement procedures to ensure the admissions checklists are properly completed.

Corrective Action: 1. The Admissions Technician will verify that all student files have a label inside the folder and the label should be completed at the time they start at BCC or return to BCC. 2. The Registrar will work closely with the Admissions Technician to assure that all required documents are in the files prior to them being transferred to the Registrar's Office. Most importantly so that the Registrar can verify a student's enrollment in a federally recognized tribe. ? The Admissions Technician will have all required supplies on hand prior to the start of any semester. ? The Registrar will strengthen the procedures and timeline for the Admissions Technician to adhere to for student files to be completed. ? The Registrar will continue to assure that the Admissions Technician budget has funding for a temporary file clerk to assist with completion of this task by the 4th week of every semester. ? The Admissions Technician will continue to work with the Financial Aid Office and the Student Accounts Technician so that students bring in required paperwork prior to receiving their reimbursements. ? The Admissions Technician will also contact students via mail, email, and other options available under the new Blackbaud system to make sure all files are completed prior to the 4th week of the semester. ? The Admissions procedure manual will be revised to include this change of procedure and the new timeline.

2016-003