Joint School District No. 28-J of the Counties of Adams and ArapahoeLocal Government

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Each year, based on the maximum Pell Grant established by Congress, the Department of Education provides to institutions payment and disbursement schedules for determining Pell Grant Awards. The payment schedule provides the maximum scheduled award a student would receive for a full academic year as a full time student based on the student aid index (SAI) and cost of attendance (COA). The disbursement schedules are used to determine annual awards for different enrollment intensities. All schedules, however, are based on a school operating a credit hour program. Per Volume 7, Chapter 4 of the Student Financial Aid Handbook, under a clock hour program, all students are considered full time students (100% intensity) in terms of financial aid calculations unless they are attending less than half time (0-40% intensity). Condition - The School District awarded aid to students using the full time, three quarter time, half time, etc schedule and improperly recorded students under a credit program versus appropriately recording them under a clock hour program, for which students would have been considered full time in their enrollment status if they did not attend less than half time. Questioned Costs - Unknown If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - The School District does not maintain accurate cost of attendance calculations needed in order to determine the amount of the financial aid to be awarded to students. Identification of How Questioned Costs Were Computed - N/A Context - Of the 40 students tested, 33 students were provided PELL grants using the three quarter or half time schedules and were not considered full time students (100% intensity) in terms of financial aid awards. Cause and Effect - The school district did not follow financial aid guidelines for clock hour programs accurately, treating students as three quarter time or half time instead of full time for financial aid awards. The institution under awarded Pell Grant funds to eligible students, potentially impacting their ability to afford educational expenses. Recommendation - We recommend the institution implement policies and procedures that follow clock hour institution guidelines to ensure Pell Grant awards are accurately calculated. Staff should receive training on award recalculation procedures and system validation tools. Views of Responsible Officials and Corrective Action Plan - The School District agrees with the finding. The School District has consulted with its third-party vendor to begin processing the maximum Pell Grant awards to all students in which they are eligible. This began in the Fall of 2025.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass- through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per the Student Financial Aid Handbook Volume 3, Chapter 2, school districts must establish and maintain accurate cost of attendance (COA) components, including both direct and indirect costs, to determine student eligibility and award amounts for Title IV aid. The COA must reflect reasonable estimates of expenses students are likely to incur. Per the Student Financial Aid Handbook, Volume 3, Chapter 3, financial aid awarded to students, including federal and non federal aid, is limited to the student's calculated cost of attendance. Condition - The School District did not utilize the cost of attendance when determining the maximum amount of aid a student is eligible to receive. The School District also does not maintain updated cost of attendance calculations for its programs. Questioned Costs - Unknown If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - The School District does not maintain accurate cost of attendance calculations needed in order to determine the amount of the financial aid to be awarded to students. Identification of How Questioned Costs Were Computed - N/A Context - The cost of attendance was not updated since 2014 for some programs, therefore creating the inability to recalculate the award determination for student's financial aid. Cause and Effect - The School District lacked a formal process for annually reviewing and updating indirect cost estimates within the Campus Ivy portal and did not utilize the COA in determining the maximum award students maybe eligible for. Not utilizing the COA in award determinations may have led to improper distributions of PELL grants. Recommendation - We recommend the School District implement a documented process for annually reviewing and updating all components of the cost of attendance, including indirect costs. This process should include market research, student surveys, and coordination with institutional departments to ensure estimates are reasonable and support accurate aid packaging. We also recommend the School District adopt policies and procedures to account for the COA when calculating PELL grant awards. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is developing a documented annual process to review and update all components of the cost of attendance, including indirect costs, using market research, student input, and coordination with relevant departments. The District is also revising its policies and procedures to ensure the cost of attendance is properly applied when calculating Pell Grant awards. These updates will support more accurate aid packaging and ongoing compliance with federal requirements.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 34 CFR 690.83(b), changes in a student's status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change. Condition - The School District did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - Noncompliance with reporting requirements, no direct financial impact identified. Identification of How Questioned Costs Were Computed - N/A Context - There were four errors identified that were attributed to this finding. 1) The school district relied on a third party service to report information to the NSLDS and did not verify the information reported by the third party for accuracy. 2) Of the 48 students tested, there were 47 students who withdrew/graduated whose status change was not accurately reported to the NSLDS. 3) Of the 48 students tested, there were 5 students whose status did not agree between the campus level data and program level data reported to the NSLDS. 4) Of the 48 students tested, there was 1 student who graduated whose status was unable to be located in the NSLDS system. Cause and Effect - The School District did not have a control in place to ensure all enrollment changes are reported accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in an accurate manner. Recommendation - The School District should implement controls to ensure student status changes are reported accurately to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing enhanced controls to ensure all student status changes are accurately reported to NSLDS, including a detailed review of enrollment rosters prior to submission. Staff have received updated guidance on the new procedures, and the District will conduct periodic checks to verify ongoing accuracy and compliance.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 34 CFR 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 assistance 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, 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 - The School District does not calculate or process any post withdrawal disbursements for students that have withdrawn from the institution. Questioned Costs - Unknown If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - The School District does not maintain accurate cost of attendance calculations needed in order to determine the amount of the post withdrawal disbursements for students who withdrew during the fiscal year. Identification of How Questioned Costs Were Computed - N/A Context - During our discussion and testing of Return of Title IV Funds (R2T4) calculations, we identified that the institution did not process or offer post withdrawal disbursements to students who withdrew prior to the 60% mark of the semester in which tuition is charged to the student account. We identified two students from the population of withdrawn students who withdrew after the start of the semester and before tuition was applied. Although the students incurred costs, such as transportation, housing, books, etc. the School District did not process post withdrawal disbursements for the students. Cause and Effect - The institution’s R2T4 procedures did not include a review for post withdrawal disbursement eligibility. Staff were unaware of the requirement to offer and process post withdrawal disbursements for earned aid. Eligible students did not receive Title IV funds they had earned prior to withdrawal, resulting in potential underfunding and noncompliance with federal regulations. Recommendation - We recommend the School District revise its R2T4 procedures to include a formal review for post withdrawal disbursement eligibility and ensure timely notification and processing of earned aid. Staff should be trained on federal requirements related to post withdrawal disbursements. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is revising its R2T4 procedures to include a formal review of post-withdrawal disbursement eligibility and will ensure timely notification and processing of any earned aid. Staff are being trained on applicable federal requirements and the updated procedures to maintain full compliance.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 668.164(I), when students are issued a check for aid earned in excess of tuition and fees collected by the School District, students have 240 days to cash the check. Any uncashed funds after 240 days must be returned to the Department of Education and cannot be escheated to the State. Condition - The institution's policy maintains that any uncashed check must be escheated to the State of Colorado after the financial statement year end to the Great Colorado Payback program and does not include a carve out for uncashed Title IV aid checks. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No outstanding disbursements beyond 240 days were identified during the audit period and no funds were escheated to the state during the period under audit. Identification of How Questioned Costs Were Computed - N/A Context - The School District maintains a written policy that directs unclaimed Title IV funds to be returned to the State of Colorado through the Great Colorado Payback program, rather than to the U.S. Department of Education as required under federal regulations. During fiscal year 2024, there were no uncashed checks after the 240 time period and therefore, no funds were reverted to the State of Colorado. Cause and Effect - The School District was unaware of the specific regulatory requirement and had not updated its disbursement policy to reflect current federal guidelines. Although no disbursements were made in violation during the audit period, the institution’s policy is noncompliant with Uniform Guidance. Recommendation - We recommend the institution revise its disbursement policy to align with the requirement that all uncashed Title IV funds be reverted to the Department of Education. Staff responsible for financial aid disbursements should be trained on federal timing requirements. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is revising its disbursement policy to ensure all uncashed Title IV funds are returned to the Department of Education in accordance with federal requirements. Staff responsible for financial aid disbursements are receiving training on federal timing and return-of-funds requirements to ensure accurate and compliant processing moving forward.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 34 CFR 668.164(h), when a Title IV credit balance occurs, the School District must pay the credit balance directly to the student or parent no later than 14 calendar days after the balance is created unless the School District obtains a voluntary authorization from the student to hold the Title IV credit balance. Condition - The institution did not reimburse students with credit balances within 14 days of the balance being posted to their student ledger. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No over award identified, but noncompliance with timing requirements. Identification of How Questioned Costs Were Computed - N/A Context - During our review of student account records and disbursement activity, we identified that the institution did not consistently remit Title IV credit balances to students within the required 14 day timeframe. Of the 60 students tested, we identified that 48 students were not paid within the required 14 day period and authorizations to hold the funds were not obtained. Cause and Effect - The institution’s disbursement procedures establish that students will receive refund checks approximately 6 to 8 weeks following the aid being applied to their student ledger. Students experienced delays in receiving funds intended to cover educational and living expenses. The institution was not in compliance with federal disbursement timing requirements. Recommendation - We recommend the institution implement automated tracking of Title IV credit balances and establish internal controls to ensure timely remittance within the 14 day requirement. Staff should be trained on federal disbursement regulations and procedures should be updated to include regular monitoring. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing automated tracking of Title IV credit balances and establishing internal controls to ensure timely remittance within the 14-day federal requirement. Staff are being trained on updated federal disbursement regulations, and procedures are being revised to include routine monitoring to ensure ongoing compliance.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 600.20, institutions must ensure that all eligible academic programs are properly reported and approved through the Eligibility and Certification Approval Report (ECAR) issued by the U.S. Department of Education. Institutions must maintain internal controls to verify that only eligible programs are included in Title IV aid processing. Condition - The institution does not have a process or controls in place for a timely review of program eligibility. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No questioned costs, no ineligible programs identified. Identification of How Questioned Costs Were Computed - N/A Context - During the audit period, the School District did not perform verification over program eligibility of the programs offered. Of the 24 programs offered by the School District, all 24 programs met Title IV eligibility requirements. There was no documented process for reviewing ECAR updates or confirming program inclusion. Cause and Effect - The institution did not have a formal process for monitoring ECAR submissions and approvals. Responsibility for program eligibility verification was not clearly assigned and there was no oversight mechanism in place. Title IV funds could have been disbursed to students enrolled in programs not officially recognized on the institution’s ECAR, resulting in noncompliance with federal program eligibility requirements. This represents a material weakness in internal control over compliance. Recommendation - We recommend the institution implement a formal control structure to ensure all academic programs are reviewed for Title IV eligibility and included on the ECAR prior to disbursing aid. This should include assigning responsibility, establishing timelines for ECAR updates, and conducting periodic reconciliations between academic offerings and approved programs. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing a process to review academic programs for Title IV eligibility and ensure they are added to the ECAR before aid is awarded. This will include identifying who is responsible for updates and setting a regular schedule to review program listings so they stay accurate.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 600.20, institutions participating in Title IV programs must ensure continued compliance with institutional eligibility requirements and maintain adequate documentation to support such compliance. Regular reviews are necessary to confirm ongoing eligibility and to identify any changes that may affect participation. Condition - The School District is eligible to participate in Title IV federal student aid programs; however, it does not conduct an annual review of its institutional eligibility requirements nor maintain documentation supporting such assessments. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No questioned costs Identification of How Questioned Costs Were Computed - N/A Context - During the audit period, the School District met Title IV eligibility requirements but the School District lacked internal controls to verify institutional eligibility prior to disbursing Title IV funds. There was no documented process for reviewing updates or confirming the eligibility requirements were met. Cause and Effect - The School District has not established formal procedures to perform and document annual reviews of its institutional eligibility status. Failure to conduct and document annual eligibility reviews may result in noncompliance with federal regulations, potentially jeopardizing the institution’s continued participation in Title IV programs. Recommendation - We recommend the School District implement a formal process to conduct annual reviews of its institutional eligibility requirements and maintain appropriate documentation of these assessments. This process should include a checklist of eligibility criteria, responsible personnel, and a timeline for completion. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing a regular process to review institutional eligibility annually and document the results. This will include using a checklist of requirements, identifying who is responsible for each step, and setting a clear timeline to ensure the review is completed consistently.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, School Districts are required to establish and maintain effective internal controls over compliance with federal statutes, regulations, and the terms and conditions of federal awards. This includes oversight of third party service providers that manage key systems used in the administration of Title IV programs. Controls over the third party service providers should include access to systems and data, change management, data backup and recovery, and system operations and monitoring. Condition - The School District relies on two third party vendors to manage key financial aid systems, including student information, eligibility determinations, disbursement calculations, and reporting. During the audit period, the institution did not perform any oversight activities or testing to verify the integrity, accuracy, or compliance of the systems managed by the vendor. There were no documented controls, service level agreements, or monitoring procedures in place. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - No questioned costs Identification of How Questioned Costs Were Computed - N/A Context - The School District utilizes two third party vendors to manage key financial aid systems. The School District relies on the controls embedded into the systems by the third party vendors; however, the School District does not perform any internal control reviews over one of the systems. Cause and Effect - The School District did not have a formal process for evaluating or monitoring third party service providers. Roles and responsibilities for oversight were not clearly defined, and there was a lack of awareness regarding federal requirements for vendor accountability. The absence of oversight and testing over third party systems increases the risk of undetected errors, data integrity issues, and noncompliance with Title IV requirements. This represents a material weakness in internal control over compliance. Recommendation - We recommend the institution establish formal oversight procedures for third party service providers managing Title IV systems. This should include documented agreements, regular performance reviews, system access controls, and periodic testing of data accuracy and compliance. Responsibilities should be clearly assigned to ensure ongoing monitoring. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is implementing oversight practices for its third-party service providers, including maintaining written agreements and setting expectations for regular check-ins and performance reviews. Responsibilities for monitoring will be assigned to ensure ongoing attention to system accuracy and support needs.

Assistance Listing, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Pell Grant Program ALN 84.06 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 34 CFR 668.16, School Districts must verify student eligibility and ensure accurate review of ISIR data before disbursing Title IV aid. Failure to do so constitutes noncompliance with federal regulations. Condition - The School District does not properly review students' institutional Student Information Records (ISIR) to determine that the student is eligible for federal student financial aid. If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - None Identification of How Questioned Costs Were Computed - N/A Context - The School District relies on their third party service provider to evaluate ISIRs and does not have internal control processes in place to verify eligibility prior to disbursing Title IV aid. Cause and Effect - The School District has not implemented a formal policy or procedure requiring the review and documentation of ISIR data prior to determining student eligibility for federal financial aid. Failure to review ISIRs may result in the disbursement of Title IV funds to ineligible students, leading to potential noncompliance with federal regulations and a risk of financial liability to the School District. Recommendation - We recommend that the School District enhance its internal controls over ISIR review and verification procedures. This should include staff training, implementation of standardized review checklists, and system level safeguards to prevent disbursement prior to eligibility confirmation. Views of Responsible Officials and Planned Corrective Actions - The School District agrees with the finding. The School District is strengthening its ISIR review process by implementing standardized checklists and updating procedures to support consistent eligibility review. Staff are receiving additional training on these steps, and the District is working to put system safeguards in place to ensure eligibility is confirmed before aid is disbursed.

2022-001 Finding: Reporting Federal Assistance Listing Number 84.425E - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion Department of Education Award Number ? P425E205475 Award Year ? 2021-2022 Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report. Condition: The District had not posted the required Student Aid information for the third quarter, which was required to be posted publicly to the District's website during the fiscal year ending June 30, 2022. Questioned Costs: None noted. Context: Four quarterly Student Aid reports for fiscal year 2022 were to be posted on the District's website by the federal due dates to comply with federal regulations. The third quarter report was not posted. Effect: Federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. The District is not in compliance with the requirements of the award. Cause: There was confusion surrounding the required reporting. The institutional reporting continued as required. A new form was provided by the federal government to be completed and made publicly available but it only included institutional information thereby causing the student information to be inadvertently excluded. Recommendation: We recommend that the District take immediate action to post the missing report to the website, obtain clarification for any confusing, ambiguous or complex compliance requirements, and stay diligent in staying abreast of the specific reporting requirements. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

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