SAN JUAN COLLEGEHigher Education

Federal program information: Funding agency: All Programs Title: All Programs Federal Assistance Listing Number: All Programs Compliance Requirement Reporting Award Period: July 1, 2022 to June 30, 2023 Condition: The College’s fiscal year ended June 30, 2023, single audit reporting package was not submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period as required by 2 CFR Section 200.50(c). Criteria: The Uniform Guidance requires that the Single Audit reporting package be submitted within nine months after the end of the audit period. Effect: The College is not in compliance with reporting requirements of the Uniform Guidance. Questioned Costs: None Cause: The College experienced significant turnover during this fiscal year, and it resulted in both operations and closing of the previous fiscal year to be delayed which made everything late. Auditors’ Recommendation: We recommend that the College should work to catch up the closing process in order to ensure that the next year’s audit is performed timely in order for the next year’s audit reporting package to be submitted by the federal clearing house due date. Agency’s Response: With the ERP conversion project mostly behind it, and a key staff vacancy filled, the College fully expects that in FY24 it will again be to resume its long-time pattern of timely filing its Single Audit reporting package incompliance with the Uniform Guidance. The Controller and/or Assistant Controller(s) are responsible for insuring success in this.

Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster Assistance Listing number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2021 to June 30, 2022 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the Return of Title IV funds, we noted the following noncompliance: ? In 3 out of 25 students examined, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student. ? One student?s calculation of return of funds was incorrect, the amount of funds returned should have been $520 but $887 was returned to the Department of Education. The College did not make complete progress in fiscal year 2022. Criteria: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education Department as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. According to 34 CFR 668.22(g), The institution must return the lesser of (1) the total amount of unearned Title IV assistance to be returned as described above, or (2) an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. If, for a non-term program, an institution chooses to calculate the treatment of Title IV assistance on a payment period basis, but the institution charges for a period that is longer than the payment period, ?total institutional charges incurred by the student for the payment period? is the greater of (1) the prorated amount of institutional charges for the longer period, or (2) the amount of Title IV assistance retained for institutional charges as of the student?s withdrawal date. Questioned Costs: None Effect: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements and because of one student?s miscalculation of returned funds, the College sent $367 more to the Department of Education than the required amount. Cause: The College was late in sending the returned funds to the Department of Education for a few of our samples examined because the financial aid office was not made aware certain students were no longer attending the College until after the end of the semester. The calculated dates for return of funds are the last date the student attended the College which meant that the College?s staff would not be informed of the withdrawal until after the 45 days was lapsed. All three of these instances had money transferred within 45 days of the semester end. The incorrect calculation of the one student occurred when there was a change in the student?s status of loan funds awarded; the change was not updated appropriately in the College?s system (Colleague), which resulted in the incorrect calculation. Auditor?s Recommendations: We recommend that the College ensure that the professors inform the financial aid office as soon as a student is no longer attending classes so that the College can ensure they send the Return of Title IV funds within the required 45 days and that when calculating the return of funds, the staff review to ensure they have taken into account all changes of the student status. Agency Response: Management agrees with this finding to meet compliance with the 45 day return of Title IV funds. ? Financial Aid is running a weekly report to capture all students that have dropped/withdrawn from classes. At the end of the semester (fall, spring or summer), a report is run to identify withdrawals, failed, or incomplete grades to determine if a return of funds calculation is warranted. This became important with the impact of COVID-19 on students which caused disruptions and difficulty in managing course loads. Financial Aid processes had a built in assumption that failed grades were unearned but, in reviewing and updating our processes most failed grades are actually earned. The return of funds has traditionally been calculated with the assumption the student did not earn the failed grade so the mid-point of the term was used for last date of attendance. Financial Aid is updating processes based on actuals and will continue working with Learning on the most efficient methodology to determine if a student has earned a failed grade or has stopped attending during the semester. ? Financial Aid will generate a weekly report to identify student withdrawals utilizing a new reporting tool being implemented late 2021. With the enhanced reporting tool and changes in methodology and process?s, we fully anticipate the return of funds will be calculated and remitted to the Department of Education within the required time. ? The Financial Aid Office has communicated with the Vice-President of Learning about the necessity for proper reporting by faculty with regards to non-attendance reporting and last date of attendance. ? Timeline: Management has already implemented the corrective actions. ? Mindi Schrum, Sr. Director and/or Greg Gallegos, Assistant Director will oversee the implementation of these.

2021-004 ? Return of Title IV Funds (Significant Deficiency) Repeated and Modified from FS 2020-003 Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2020 to June 30, 2021 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the Return of Title IV funds we noted the following noncompliance: ? In 8 out of 25 students examined, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student. Criteria: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education Department as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. According to 34 CFR 668.22(g), The institution must return the lesser of (1) the total amount of unearned Title IV assistance to be returned as described above, or (2) an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. If, for a non-term program, an institution chooses to calculate the treatment of Title IV assistance on a payment period basis, but the institution charges for a period that is longer than the payment period, ?total institutional charges incurred by the student for the payment period? is the greater of (1) the prorated amount of institutional charges for the longer period, or (2) the amount of Title IV assistance retained for institutional charges as of the student?s withdrawal date. Questioned Costs: None Cause: The College was late in sending the returned funds to the Department of Education for many of our samples examined because the deadline for sending the funds either occurred during the winter break or soon after the winter break. The College?s staff also were not in the College?s offices during part of the year due to the COVID-19 pandemic which caused delays. Of the eight late students tested, six of them were unofficial withdrawals which meant the College?s staff was not made aware of the withdrawal until after the semester ended but had calculated dates that were at the mid-point of the semester which meant that the College?s staff would not be informed of the withdrawal until after the 45 days was lapsed. Five of these instances had money transferred within 45 days of the semester end. Effect: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements. Auditor?s Recommendations: We recommend that the College adjust their process(es) regarding the timing of the Return of Title IV funds for the Official withdrawals to ensure that they are remitting the funds to the Department of Education within the 45-days as required. Agency Response: Management agrees with this finding to meet compliance with the 45 day return of Title IV funds. ? Financial Aid is running a weekly report to capture all students that have dropped/withdrawn from classes. At the end of the semester (fall, spring or summer), a report is run to identify withdrawals, failed, or incomplete grades to determine if a return of funds calculation is warranted. This became important with the impact of COVID-19 on students which caused disruptions and difficulty in managing course loads. Financial Aid processes had a built in assumption that failed grades were unearned but, in reviewing and updating our processes most failed grades are actually earned. The return of funds has traditionally been calculated with the assumption the student did not earn the failed grade so the mid-point of the term was used for last date of attendance. Financial Aid is updating processes based on actuals and will continue working with Learning on the most efficient methodology to determine if a student has earned a failed grade or has stopped attending during the semester. ? Financial Aid will generate a weekly report to identify student withdrawals utilizing a new reporting tool being implemented late 2021. With the enhanced reporting tool and changes in methodology and process?s, we fully anticipate the return of funds will be calculated and remitted to the Department of Education within the required time. ? The Financial Aid Office has communicated with the Vice-President of Learning about the necessity for proper reporting by faculty with regards to non-attendance reporting and last date of attendance. ? Mindi-Kim Schrum, Sr. Director and/or Gary Gallegos, Assistant Director will oversee the implementation of these.

Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2020 to June 30, 2021 Compliance Requirement: Special Tests and Provisions Condition: During our verification testwork, we noted deviations from the College?s key controls over the verification process. Students are flagged to be verified in the Colleague system by the Department of Education and this is completed by one of the College?s employees, reviewed and approved by a student advisor who is deemed by the College to be a qualified person to ensure accuracy of the verification. Our examination revealed the following: ? In 3 out of 53 verifications examined, we noted that there was no evidence of a verification form for the current year under audit, there was evidence of this being completed for these students in past school years but not for fiscal year 2021 for which they were chosen to receive an updated verification completed. ? In 1 out of 53 verifications examined, we noted that there was no documented review on the verification worksheet documenting evidence of a review of the worksheet. Criteria: According to 34 CFR 668.51 through 668.61, an institution is required to establish written policies and procedures for verifying applicant information. Questioned Costs: None Cause: The College either did not perform an updated verification for fiscal year 2021 or the documentation of the verification was not retained as required by the College?s procedures for review of the auditor. For the missing signature, the student advisor either did not review the verification tested or reviewed but did not sign off that they reviewed the worksheet. Effect: San Juan College is in violation of its internal controls over compliance of having a student advisor review all verification worksheets for the Student Financial Aid Program. Auditors? Recommendation: We recommend that San Juan College ensure that all verification worksheets are reviewed, filed and signed to document that reviews have been performed. Agency Response: Management agrees with the finding and recommendations. Due to the COVID-19 pandemic, financial aid advisors worked diligently to follow all compliance items regarding internal controls. Duplicate files were created for review, records in question did not get initialed due to duplication. ? Operating efficiencies were gained using electronic resources for managing student data. Advisors now have the ability to upload student information, review, update and award through the ERP system. If information is missing, the record stays in the queue and students is electronically notified that additional information is needed. Verification and controls are built into the electronic processes, which not only allows for a clean review it also enhances internal controls. The advisor signature field must be complete before awarding can take place, which insures verification has been properly completed. ? Mindi-Kim Schrum, Sr. Director and/or Gary Gallegos, Assistant Director will oversee the process.

GSA_MIGRATION

2019-002 - Notification of Disbursements of Loan Funds (Noncompliance and Significant Deficiency)) Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2019 to June 30, 2020 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the disbursements of federal loans to students, we noted 2 out of 25 students tested were first semester students who received their student loan funds within the first 30 days of the student?s first day of classes. The College has made some progress towards implementing their corrective action plan from the prior year and are working on completing the implementation of their plan during fiscal year 2021. Criteria: According to 34 CFR 668.164(i)(2), Institutions may not disburse or deliver the first installment of direct loans to first-year undergraduates who are first time borrowers until 30 days after the student?s first day of classes. Questioned Costs: None Cause: The College disbursed the loan funds for all students approximately the same time period for the semesters without reviewing to verify which students were first-year undergraduates. Effect: The College is out of compliance with the disbursements to students for the Direct Student Loans. Auditor?s Recommendations: We recommend that the College adjust their process(es) regarding the timing of disbursements of student loans to ensure any new first-year undergraduates do not receive their student loan funds until 30 days after their classes start. Agency Response: ? Management agrees with the finding and recommendations to address the student loan processes regarding first time borrowers. Financial Aid has already created and implemented a query to identify first time borrowers in order to cross reference the loan code assigned. ? Advisors have received and will continue additional training on all direct loan borrowing processes. A requirement will be established, in FY21, for advisors to review students loan history in the National Student Loan Data System (NSLDS) before processing a loan. If the student has never borrowed or previously borrowed a loan period code with an automatic 30-day delay will be assigned. The code automatically sets the first disbursement to 30 days after the start of the semester for specific borrowing period based on established rules. ? The Sr. Director and/or the Assistant Director will monitor the policies and procedures to ensure they are being followed correctly.

2020-003 ? Return of Title IV Funds (Significant Deficiency) Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2019 to June 30, 2020 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the Return of Title IV funds we noted the following noncompliance: ? In 11 out of 25 students tested, the College did not return the funds to the Department of Education in the required 45 days after the withdrawal date of the student. ? One student?s calculation of return of funds that was incorrect; the amount of funds returned should have been $1,042, but only $152 was returned to the Department of Education. Criteria: According to 34 CFR 668.173(b), return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance account or electronic fund transfers initiated to the Education Department as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. According to 34 CFR 668.22(g), The institution must return the lesser of (1) the total amount of unearned Title IV assistance to be returned as described above, or (2) an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. If, for a non-term program, an institution chooses to calculate the treatment of Title IV assistance on a payment period basis, but the institution charges for a period that is longer than the payment period, ?total institutional charges incurred by the student for the payment period? is the greater of (1) the prorated amount of institutional charges for the longer period, or (2) the amount of Title IV assistance retained for institutional charges as of the student?s withdrawal date Questioned Costs: None Cause: The College was late in sending the returned funds to the Department of Education for many of our samples examined was because the deadline for sending the funds either occurred during the winter break or soon after the winter break. The College?s staff were catching up on many tasks before getting to the return of funds. The incorrect calculation of the one student occurred when there was a change in the student?s status of loan funds awarded; the change was not updated appropriately in the College?s system (Colleague), which resulted in the incorrect calculation. Effect: The College returned Title IV funds to the Department of Education later than the timeframe required by the program requirements. Auditor?s Recommendations: We recommend that the College adjust their process(es) regarding the timing of the Return of Title IV funds to ensure that they are remitting the funds to the Department of Education within the 45-days as required. We also recommend that student?s calculation of the return of funds be reviewed after any changes have been made to their status. Agency Response: ? Management agrees with this finding and recommendations to meet compliance with the 45 day return of Title IV funds. Financial Aid has already updated their policy and procedures to include running a weekly report to capture all students that have disenrolled from classes. In FY21 the return of funds will be calculated and remitted to the Department of Education within the required time. ? The Sr. Director and/or the Assistant Director will oversee the implementation of these.

2020-004 Controls over Verification of Students for the Student Financial Aid Program (Significant Deficiency) Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2019 to June 30, 2020 Compliance Requirement: Special Tests and Provisions Condition: During our verification testwork, we noted deviations from the College?s key controls over the verification process. Students are flagged to be verified in the Colleague system by the Department of Education and this is completed by one of the College?s employees, reviewed and approved by a student advisor who is deemed by the College to be a qualified person to ensure accuracy of the verification. In 3 out of 40 verifications tested, we noted that there was no documented review on the verification worksheet showing evidence of a review of the worksheet. Criteria: According to 34CFR 668.51 through 668.61, an institution is required to establish written policies and procedures for verifying applicant information. Cause: The student advisor either did not review the verifications tested or reviewed but did not sign off that they reviewed the worksheet. Effect: San Juan College is in violation of its internal controls over compliance of having a student advisor review all verification worksheets for the Student Financial Aid Program. Auditors? Recommendation: We recommend that San Juan College ensure that all verification worksheets are reviewed and signed to document that reviews have been performed. Agency Response: ? Management agrees with the finding and recommendations. Advisors failed to sign off on the completed verification worksheets and a review was not performed. To ensure proper procedures are followed by the advisors including signing off on compleded worksheets, effective in the first half of FY21 an independent review will be performed by another advisor or other qualified personnel to verify completion. ? The Sr. Director and/or the Assistant Director will oversee the process.

2019-002 - Notification of Disbursements of Loan Funds (Noncompliance and Significant Deficiency) Federal program information: Funding agency: U.S. Department of Education Title: Student Financial Assistance Cluster CFDA number: 84.007, 84.033, 84.063, & 84.268 Award year: July 1, 2018 to June 30, 2019 Compliance Requirement: Special Tests and Provisions Condition: In our testwork over the disbursements of federal loans to or on behalf of students, we noted 14 out of 25 students tested that did not receive their notification letter within the required 30-day period before or after the date of disbursement. Criteria: According to 34 CFR 668.165, Institutions that implement an affirmative confirmation process must make a notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student?s account at the institution with Direct Loan or TEACH grants. Questioned Costs: None Cause: The College attempted to get ahead on their workload and send out many of the notification letters early in the summer for both the fall and spring semesters. Effect: The College is out of compliance with the notification requirements set for Direct Student Loans. Auditor?s Recommendations: We recommend that the College adjust their process(es) over the timing of notifications with regards to the disbursements of student loans to ensure all notification letters for loan disbursements are sent either 30 days before or 30 days after the disbursement of funds. Agency Response: Effective with the 2019-2020 academic year, the Financial Aid Office has revised its notification process for loan notification procedures under 34 CFR 668.165 to insure that the required notification is being sent by email on the date the disbursement happens. The contact person responsible for monitoring and maintaining corrective procedures is the Senior Director of Financial Aid and the Vice President of Student Services.