Pima County Community College DistrictHigher Education

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: P007A230133, P033A230133, P063P230512, P063Q230512, and P268K230512 July 1, 2023 through June 30, 2024 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions - return of Title IV funds Questioned costs: $943 Condition—Contrary to federal regulation and the District’s policies and procedures, the District’s Financial Aid and Scholarships Department (Department) did not return $943 of Student Financial Assistance’s (SFA) Title IV funds for 1 student who received grants and loans and withdrew during a payment period or period of enrollment in which the student began attendance.1 Specifically, for 1 of 25 students tested, the District did not complete the required calculation and return the $943 unearned portion of a student’s $3,698 original Pell grant award to the U.S. Department of Education (ED) after the student withdrew from the District. Effect—The District’s not returning $943 of Title IV funds to ED resulted in Title IV funds not being spent as intended by program requirements. Further, there is an increased risk that the District may need to return additional Title IV funds to ED. For example, the Department’s Management reported that it identified an additional 81 students, or $153,318 in Title IV funds, for whom it did not perform required calculations during the period November 2023 through June 30, 2024. This includes $143,509 in Pell Grants, $5,718 in Direct Loans, $3,716 in Federal Work Study, and $375 in Federal Supplemental Educational Opportunity Grants that may not have been spent as intended by program requirements. Cause—The District’s student information system’s automated controls did not flag students who withdrew and required a return to Title IV calculation. In November 2023, the District made changes to its student information system without performing tests to ensure the automated controls were properly identifying and flagging students who withdrew. Criteria—Federal regulation and District policies and procedures require the return of Title IV funds when a recipient of Title IV grant or loan assistance withdraws from the District during a payment period or period of enrollment in which the recipient began attendance. Specifically, the District must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs (34 Code of Federal Regulations [CFR] §668.22[a][1-5]).2 Further, 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 Department should: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. 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 and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The Title IV programs as part of the Student Financial Assistance cluster are administered by the Department of Education (those with Assistance Listings beginning with 84) and authorized by Title IV of the Higher Education Act of 1965, as amended (HEA), and collectively are referred to as the “Title IV programs.” 2 Pima County Community College District. (2023). Pima County Community College District Policy and Procedures 2023-2024 V2. Page 253 of 272.

Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award numbers and years P425E200055, April 20, 2020 through June 30, 2023; P425F201359, May 6, 2020 through June 30, 2023; P245L200182, June 2, 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?s Grant Services Department and the Financial Aid and Scholarships Department failed to make complete and accurate quarterly reports publicly available on the District?s website for the program?s student, institutional, and MSIs portions (Assistance Listings numbers 84.425E, 84.245F, and 84.425L, respectively). Specifically, the District did not complete and publicly post reports for the quarters ended March 31, 2022 and June 30, 2022, until January 2023, which was after we notified the District that the reports were missing from its website. In addition, for 2 of 3 reports we tested, the District overreported and underreported program expenditures by $1,558,400 and $9,806, respectively, for the student and MSIs portions (Assistance Listings numbers 84.425E and 84.425L). Further, the District did not retain documentation supporting the amounts it reported. Effect?The District?s failure to make complete and accurate quarterly reports available on the District?s website resulted in a lack of transparency to the public for how it spent federal COVID-19 Educational Stabilization Fund monies for program purposes. Cause?The personnel who had been administering the program left the District, and the new employees responsible for administering the program reported that they were not aware of the federal reporting requirement to post the reports on the District?s website and, therefore, did not properly coordinate the reporting requirements between the Grant Services Department and Financial Aid and Scholarships Department as both were responsible for the report. Further, the District did not follow the Grant Services Department?s written policies and procedures to track federal program reporting requirements to ensure that all reports were completed accurately and on time. Finally, an independent review was not performed for each section of the reports to ensure that they were complete and accurate. Criteria?Federal agency guidance requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the Education Stabilization Fund no later than 10 days after the calendar quarter.1 In addition, the federal Uniform Guidance requires the District to maintain program financial and accounting records and supporting documents relating to federal programs for at least 3 years from the date of the final expenditure report (2 Code of Federal Regulations [CFR] ?200.334). 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 CFR ?200.303). Recommendations?The District should: 1. Follow the Grant Services Department?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. b. Require a review and approval of all reports by an independent employee to ensure they are accurate. c. Retain all documentation supporting program expenditures reported in the federal grant reports. 2. Coordinate completing federal reports when more than 1 department is responsible for contributing information to the report to ensure the report is submitted on time. 3. Complete and publish on the District?s website the required quarterly grant reports for the Education Stabilization Fund no later than 10 days after the end of the quarter. 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 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) (OMB Paperwork Reduction Act Form Control Number 1840-0849). Retrieved 1/13/2023 from https://www2.ed.gov/about/offices/list/ope/arpheerfiiiqaurterlyreporting.pdf.

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