Pinal County Community College DistrictLocal Government

Federal Agency: U.S. Department of Education Cluster Name: Student Financial Assistance Cluster Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Federal Work Study Program Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A240134; P033A240134; P063P242910;P268K242910 - 2024 Award Period: July 01, 2023 - June 30, 2024 Compliance Requirement: Special tests and provisions Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters. Criteria or specific requirement: Once a student's withdrawal date is determined, a school needs to calculate the percentage of the payment period or period of enrollment completed. Institutionally scheduled breaks of five or more consecutive days are excluded from the return of Title IV calculation as periods of nonattendance and, therefore, do not affect the calculation of the amount of Federal Student Aid earned (34 CFR 668.22(f)(2)(i)). Condition: During our testing, it was noted the College's process did not ensure scheduled breaks were properly factored into the R2T4 calculations for both the Fall 2023 and Spring 2024 term. Questioned costs: $109.45. Context: The College did not correctly factor in scheduled breaks to 12 of the 17 students tested for Fall 2023 and 18 of the 18 students tested for Spring 2024. The College did not include the 5 day break for Thanksgiving for the Fall 2023 Semester and used 6 days of scheduled spring break instead of the entire spring break of 9 days in the Spring 2024 calculations. Cause: Management did not have a process in place to exclude the correct amount of days in the scheduled breaks of 5 days or more. Effect: The College did not complete an accurate calculation as defined by Federal regulations. Repeat Finding: Yes- 2023-001. Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations. Views of responsible officials: There is no disagreement with the audit finding, see District's corrective action plan.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A220134, P033A220134, P063P222910, and P268K232910; July 1, 2022, through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $8 Condition—Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $8 of returns of student financial assistance monies it reported in the federal agency’s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $8. In addition, for 2 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government within the required 45 days after the student’s withdrawal from classes, as the District returned these students’ monies 4 days and 17 days late. Effect—Because of the District’s inaccurate calculation in the COD system, a student was owed a refund of $8 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause—District management reported it intended to strengthen its policies and procedures to require an independent review of the calculation, but, because of program management turnover, it was unable to prioritize these revisions. Further, District management reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria—Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District’s determination that the student withdrew (34 Code of Federal Regulations [CFR] §§668.22 and 668.173). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-102 and was initially reported in fiscal year 2021.

Assistance Listings numbers and names: 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Portion 84.425F COVID-19 Education Stabilization Fund?HEERF Institutional Portion Award numbers and years: P425F200330-20B, May 4, 2020 through June 30, 2023; P425E200689-20B, April 21, 2020 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal regulations and guidance, the District Business Office failed to make complete, accurate, and timely reports publicly available on the District?s website for the program?s student and institutional portions (Assistance Listings numbers 84.425E and 84.245F, respectively). Specifically, on the District?s 2021 annual report, the Office omitted $1,228,424 it spent from the program?s institutional portion to discharge students? outstanding account balances. We found in testing the District?s quarterly reports that this amount was spent during the period of July 1, 2021 through December 31, 2021, and properly reported by the District in their quarterly reports for September 30, 2021 and December 31, 2021; however, the Office omitted this amount from its 2021 annual report. Additionally, the Office completed and publicly posted its 8 quarterly reports, including 4 institutional and 4 student reports on its website late, including anywhere from 12 to 327 days after the quarter?s end. Effect?The Office?s failure to submit a complete and accurate annual report to the U.S. Department of Education prevents the federal agency from properly monitoring that the District spent the COVID-19 Education Stabilization Fund monies in accordance with the program requirements. In addition, failure to post completed quarterly reports on the District?s website in a timely matter resulted in a lack of transparency to the public for how it spent federal monies for program purposes. Cause?Although the Office had policies and procedures for reviewing federal grant reports, the assigned reviewer did not perform a sufficiently detailed review and verify the financial information reported in the annual report agreed to the quarterly reports and accounting records. Further, the Office did not update the District?s grant schedule to post the quarterly reports on the District?s website by the designated due dates. As a result, District employees involved in completing the quarterly reports were unaware of their due dates for making them publicly available on the District?s website. Criteria?Federal agency guidance requires the District to prepare and submit an annual performance report for the COVID-19 Education Stabilization Fund, which includes information specified by federal agency guidance.1 Federal law and federal agency guidance also requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the COVID 19 Education Stabilization Fund no later than 10 days after the calendar quarter.2 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 Code of Federal Regulations [CFR] ?200.303). Recommendations?The Office should: 1. Follow the Office?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Verify that all federal expenditures are properly included in the annual report. b. Require a knowledgeable employee to review and approve all annual reports for accuracy to the quarterly reports and accounting records. c. Update the District?s grant schedule to track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. 2. Ensure that employees involved in completing federal grant program reports are made aware of the reports? designated due dates, including any requirements and due dates for making them publicly available on the District?s website. 3. Complete and publish on the District?s website the required quarterly grant reports for the COVID-19 Education Stabilization Fund no later than 10 days after the quarter?s end. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Education. (2020). Higher Education Emergency Relief Fund (HEERF) Data Collection Form. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/HEERF_Data_Collection_Final.pdf; U.S. Department of Education. (2022). Education Stabilization Fund, Higher Education Emergency Relief Fund (HEERF) Data Collection Tool User Guide, Release 2.0. Retrieved 2/21/2023 from https://api.covid-relief-data.ed.gov/collection/api/v1/public/docs/ESF-HEERF%20User%20Guide%20Year%202.pdf; and Federal Register. Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees, 86 Fed. Reg. 91 (pp. 26213?26215) (2021). Retrieved 2/21/2023 from https://www.federalregister.gov/documents/2021/05/13/2021-10196/notice-of-public-posting-requirement-of-grant-information-for-higher-education-emergency-relief-fund. 2 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III(a)(1) Institutional Portion, (a)(2), and (a)(3). Retrieved ED prescribed report?s form and instructions (OMB Paperwork Reduction Act Form Control Number 1840-0849) 3/9/2023 from arpheerfiiiqaurterlyreporting.pdf (ed.gov).

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: $275 Condition?Contrary to federal regulations and District policies and procedures, the District did not correctly calculate $275 of returns of student financial assistance monies it reported in the federal agency?s Common Origination and Disbursement (COD) system. Specifically, for 1 of 40 students tested, the District used incorrect credit hours when calculating the refund amount it recorded in the COD, resulting in the student being owed a refund of $275. In addition, for 5 of 40 students tested, the District did not timely calculate, report, and return student financial assistance monies owed to the student or the federal government after the student?s withdrawal from classes. Effect?Because of the District?s inaccurate calculation in the COD system, a student was owed a refund of $275 from the District. Further, the District increases the risk that they may not collect monies from the student that are due back to the federal government or may not refund monies it owes to students by not calculating, reporting, and returning student financial assistance monies within the required time frame. Cause?In April 2022, the District implemented policies and procedures for the return of student financial assistance monies. However, those policies and procedures did not require an independent review of the calculations prior to their submission to the COD. Further, the District reported that it did not have sufficient staffing available to calculate, report, and process returns of student financial assistance monies within the required 45 days. Criteria?Federal regulations and District policies and procedures require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor no later than 45 days after the date of the District?s determination that the student withdrew (34 Code of Federal Regulations [CFR] ??668.22 and 668.173). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should allocate staffing and improve its policies and procedures to: 1. Accurately calculate, report, and return student financial assistance monies to the federal government or the student within the required 45 days. 2. Require an independent review of the return of student financial assistance monies calculations prior to their submission to the COD. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-102.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A210134, P033A210134, P063P212910, and P268K222910 July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition?Contrary to federal regulations, the District did not accurately report student enrollment status changes and the effective dates of those changes to the National Student Loan Data System (NSLDS) for 4 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District developed written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate during fiscal year 2021; however, the District reported that due to the impact of the COVID-19 pandemic on District operations, they were unable to fully implement them by June 30, 2022. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment status data were accurate. Criteria?Federal regulations require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2]). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should fully implement written procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.

2021-101 Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A200134, P033A200134, P063P202910, and P268K212910 July 1, 2020 through June 30, 2021 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations, the District did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 21 of 60 students we tested participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District did not report: ? Accurate enrollment status and effective date information for 12 students. ? An enrollment status change within 60 days of the enrollment change for 9 students, which were reported between 4 to 27 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District hired an individual during the Spring 2020 semester assigned to report student enrollment status changes to NSLDS; however, it had not fully developed and implemented written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate and were reported to NSLDS within required time periods. Consequently, the individual assigned to report student enrollment status changes to NSLDS did not always verify that reports being generated with student-enrollment status data were accurate and submitted on time. Criteria?Federal regulations require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2]). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should fully develop and implement written policies and procedures to: 1. Report accurate enrollment statuses and changes to the NSLDS within 60 days of a change for each student receiving Pell and Direct Loans. 2. Verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and reported to NSLDS within required time periods. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2020-102.

2021-102 Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A200134; P033A200134; P063P202910; P268K212910; July 1, 2020 through June 30, 2021 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations, the District did not correctly calculate $846 of student Return to Title IV calculations it reported in the Common Origination and Disbursement (COD) system. Specifically, for 2 of 40 students tested, the District used incorrect withdrawal dates when calculating the refund amounts it recorded in the COD, resulting in $400 of refunds not reported. In addition, for 1 of 40 students tested, the District did not report the refund amount of $446 due from the student in the COD. Effect?Because of the District?s inaccurate calculations and withdrawal dates in the COD, the District?s 3 students did not return $846 of federal student financial assistance grants and loans to the Federal government. Additionally, the District?s other students may be at risk and may not be asked to return the correct amount of federal student financial assistance grants and loans. Cause?The District reported that it performs spot-check reviews of student files to monitor its Return of Title IV calculations but did not document the results of these reviews. Further, the District did not have written policies and procedures to perform and document monitoring reviews or to designate and require employees to periodically review information on COD after it was reported for accuracy and timeliness. Criteria?Federal regulations require the District to accurately calculate, report, and return federal student financial assistance to the federal grantor in a timely manner (2 Code of Federal Regulations [CFR] ??668.22 and 668.173). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Accurately calculate, report, and return federal student financial assistance to the federal grantor in a timely manner. 2. Develop and implement written policies and procedures to: a. Perform monitoring reviews of student Return of Title IV calculations and require these reviews to be documented. b. Designate employees to periodically review information the District reported in the COD for accuracy and timeliness. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

2021-103 Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A190134; P033A190134; P063P192910; P268K202910; July 1, 2019 through June 30, 2021 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?The District did not document in its risk assessment that it considered risks for employee training and management and data disposal or that it implemented safeguards for these areas if a risk was identified. Effect?The District?s administration and information technology (IT) management may put the District?s operations and IT systems and data, including student financial aid information, at unintended and unnecessary risk, which could result in unauthorized or inappropriate access and/or the loss of confidentiality or integrity of systems and data. Cause?The District designated an individual to coordinate its information security program over its student financial aid information but relied on an informal and undocumented process and did not include all required elements. Criteria?Federal regulations require the District to perform a risk assessment to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student financial aid information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and to document a safeguard for each risk identified. The risk assessment should consider risks related to employee training and management as well as data disposal (Title 16 U.S. CFR, Parts 313 and 314, as required by the Gramm-Leach-Bliley Act, P.L. 106-102). Recommendations?The District should: 1. Ensure that its student financial aid risk assessment considers and documents the risks related to employee training and management, and data disposal. 2. Document and implement a safeguard if a risk is identified for employee training and management or data disposal. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2020-104.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A190134; P033A190134; P063P192910; P268K202910; July 1, 2019 through June 30, 2020 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations, the District did not report student enrollment status changes to the National Student Loan Data System (NSLDS) within the required time periods for 41 of 60 students we tested and did not report the correct status change dates for 7 of 60 students we tested. Effect?By failing to accurately and timely report its students? enrollment status changes to NSLDS, the District?s students may not be asked to repay student financial assistance grants and loans if or when required. Cause?The District had not developed and implemented written procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate and were reported to NSLDS within required time periods. Consequently, the individual assigned with reporting student enrollment status changes to NSLDS did not always verify that reports being generated with student enrollment data were accurate and submitted on time. Further, the District had not assigned an employee independent of submitting the enrollment status changes to review the information for accuracy until the Spring 2020 semester. Criteria?Federal regulations require the District to report to the NSLDS student enrollment status changes within 30 days of a change or include the change in status in a response to an enrollment-reporting roster file within 60 days for the Federal Pell Grant and Federal Direct Student Loans programs. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence (34 Code of Federal Regulations (CFR) ??690.83[b][2] and 685.309[b]). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal awards are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendation?The District should develop and implement procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and this data is reported to NSLDS within required time periods. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2019-102.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A190134; P033A190134; P063P192910; P268K202910; July 1, 2019 through June 30, 2020 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation, the District did not reconcile its Federal Direct Student Loans program?s cash receipts and disbursements records to the Common Origination and Disbursement (COD) system?s School Account Statement data file until March 2020. Furthermore, the monthly reconciliations performed from March 2020 through June 2020 were not complete because they did not include all necessary records. Effect?There is an increased risk that the District may not identify and resolve discrepancies between its cash receipts and disbursements records and the COD. These discrepancies would be more readily identified if the District were to conduct the required monthly reconciliations. Consequently, federal Direct Loan servicers that rely on COD information may obligate students for a loan they did not receive or that was recorded at the wrong amount and may begin charging students interest on student financial assistance loans before the student?s 6-month interest grace period has ended. Cause?The District did not have written policies and procedures in place to ensure that its records were reconciled to the COD system at least monthly from July 2019 through February 2020 and at the award?s year-end for program closeout. Criteria?Federal regulation requires monthly and program-year closeout reconciliations of the Federal Direct Student Loans program monies received to pay its students to the actual disbursement records submitted to the COD system (34 CFR ?685.300[b][5] and [9]). Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Implement effective written policies and procedures to perform the required monthly and award year-end reconciliations of its Federal Direct Student Loans cash receipts and disbursements records to the District?s information reported on the COD system and investigate and resolve any discrepancies noted. 2. Ensure that the reconciliations are complete and are performed monthly and at program-year closeout. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2019-104.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A190134; P033A190134; P063P192910; P268K202910; July 1, 2019 through June 30, 2020 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?The District did not document in its risk assessment that it considered risks for employee training and management and data disposal or that it implemented safeguards for each of these areas if a risk was identified. Effect?The District?s administration and information technology (IT) management may put the District?s operations and IT systems and data, including student financial aid information, at unintended and unnecessary risk, which could result in unauthorized or inappropriate access and/or the loss of confidentiality or integrity of systems and data. Cause?The District designated an individual to coordinate its information security program over its student financial aid information but relied on an informal and undocumented process and did not include all required elements. Criteria?Federal regulations require the District to perform a risk assessment to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student financial aid information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and to document a safeguard for each risk identified. The risk assessment should consider risks related to employee training and management as well as data disposal (Title 16 U.S. CFR, Parts 313 and 314, as required by the Gramm-Leach-Bliley Act, P.L. 106-102). Recommendations?The District should: 1. Ensure that its student financial aid information risk assessment considers and documents the risks related to employee training and management and data disposal. 2. Document and implement a safeguard if a risk is identified for employee training and management or data disposal. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A180134; P033A180134; P063P182910/192910; P268K182910/192910; July 1, 2018 through June 30, 2019 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations, the District did not report student enrollment status changes to the National Student Loan Data System (NSLDS) within the required time periods and did not report the correct status change dates for all 60 students we tested. Effect?By failing to accurately and timely report its students? enrollment status changes to NSLDS, the District?s students may not be asked to repay student financial assistance grants and loans if or when required. Cause?The District had not developed and implemented procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS were accurate and were reported to NSLDS within required time periods. Consequently, the individual assigned with reporting student enrollment status changes to NSLDS did not verify that reports being generated with student enrollment data were accurate and submitted on time. Further, the District had not assigned an employee independent of submitting the enrollment status changes to review the information for accuracy. Criteria?Federal regulations require the District to report to the NSLDS student enrollment status changes within 30 days of a change or include the change in status in a response to an enrollment-reporting roster file within 60 days for the Federal Pell Grant and Federal Direct Student Loans programs. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. (34 CFR ??690.83[b][2] and 685.309[b]) Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal awards are being managed in compliance with all applicable laws, regulations, and award terms. (2 CFR ?200.303) Recommendation?The District should: 1. Develop and implement procedures to verify that student enrollment status changes recorded on its student information system and reported to NSLDS are accurate and this data is reported to NSLDS within required time periods. 2. Assign an employee who is independent of submitting the enrollment status changes to review the information for accuracy. The District?s responsible officials? views and planned corrective action are in its corrective action plan at the end of this report. This finding is similar to prior-year finding 2018-103.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A180134; P033A180134; P063P182910/192910; P268K182910/192910; July 1, 2018 through June 30, 2019 Federal agency: U.S. Department of Education Compliance requirement: Reporting Questioned costs: Unknown Condition?Contrary to federal regulations, the District did not report accurate anticipated or actual disbursement dates and did not report its student record information in a timely manner for 8 of 40 students tested when reporting Federal Pell Grant Program information on the Common Origination and Disbursement (COD) system. Effect?By failing to accurately and timely report its students? Pell grant information to the NSLDS, the District?s students may be over or under awarded Pell monies. Cause?The District did not have policies and procedures in place to ensure students? origination and disbursement data was accurately reported to the COD system within the required time periods. Also, the District did not assign an employee who is independent of the COD reporting preparation to verify the accuracy of information reported to the COD system. Criteria?Federal regulations require reporting disbursement data, such as anticipated or actual disbursement dates and amounts, as well as student record origination data, such as a student?s social security number, enrollment date, verification status code, and cost of attendance on the COD system for the Federal Pell Grant Program within 15 days after making a payment or becoming aware of the need to adjust previously reported data. If anticipated disbursement dates are reported, the District must submit them no earlier than 7 calendar days prior to the date the District expects to disburse monies to the student. (34 CFR ?690.83[b][2] and 82 Federal Register 29061) Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms. (2 CFR ?200.303) Recommendation?The District should: 1. Develop and implement policies and procedures to accurately report students? origination and disbursement data to the COD system within required time periods. 2. Require an employee who is independent of the COD reporting preparation to verify the accuracy of information reported to the COD system. The District?s responsible officials? views and planned corrective action are in its corrective action plan at the end of this report. This finding is similar to prior-year finding 2018-102.

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and year: P007A180134; P033A180134; P063P182910/192910; P268K182910/192910; July 1, 2018 through June 30, 2019 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation, the District did not reconcile its Federal Direct Student Loans program?s cash receipts and disbursements records to the Common Origination and Disbursement (COD) system?s School Account Statement data file each month. Effect?There is an increased risk that the District may not identify and resolve discrepancies between its cash receipts and disbursement records and the COD that would have been identified if it had conducted the required monthly reconciliations. Consequently, Federal Direct Loan servicers that rely on COD information may obligate students for a loan they did not receive or that was recorded at the wrong amount and may begin charging students interest on student financial assistance loans before the student?s 6-month interest grace period has ended. Cause?The District did not have policies and procedures in place to ensure that its records were reconciled to the COD system on a monthly basis. Also, the District did not assign an employee who is independent of performing the COD system reconciliation to review the reconciliation for accuracy and timeliness. Criteria?Federal regulation requires monthly reconciliations of the Federal Direct Student Loans program monies received to pay students to the actual disbursement records submitted to the COD system. (34 CFR ?685.300[b][5]) Federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms. (2 CFR ?200.303) Recommendation?The District should: ? Develop and implement policies and procedures to perform the required monthly reconciliation of Federal Direct Student Loans data reported on the COD system to the District?s records and investigate and resolve any discrepancies noted. ? Assign an employee who is independent of performing the COD system reconciliation to review the monthly reconciliations for accuracy and timeliness. The District?s responsible officials? views and planned corrective action are in its corrective action plan at the end of this report. This finding is similar to prior-year finding 2018-104.

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