NORTH ORANGE COUNTY COMMUNITY COLLEGE DISTRICTHigher Education

Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Number: 84.425F Federal Agency: U.S. Department of Education Direct Funded by the U.S. Department of Education Criteria or Specific Requirements Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Institutional Aid Portion award to publicly post the HEERF quarterly reporting form on their website no later than 10 days after the end of each calendar quarter, or as directed by the U.S. Department of Education. Condition During our testing over reporting for the institutional aid portion at Cypress College, we noted that the report required to be publicly available by October 31, 2020 following the end of the quarter ending September 30, 2020 available was posted on January 20, 2021 and therefore, the District did not meet the timeliness requirement. Questioned Costs None reported. Context Significant Deficiency in Internal Control over Compliance - The District has two colleges that were required to report institutional grant metrics and other data within 10 days of the end of each calendar quarter, or as directed by the U.S. Department of Education. A sample of two reports from each college were reviewed for compliance, with one report not submitted in a timely manner. Effect The College?s quarterly report was not uploaded to their website within the required timeframe. Cause Changing award program guidance/documentation, focused efforts on quick distribution of funds to students, remote work environment challenges, and a transition to a new website delayed initial posting of required reports. Repeat Finding (Yes or No) No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.

Direct Programs ? Department of Education CFDA# 84.425E COVID-19 - Higher Education Emergency Relief Funds ? Student Share Reporting Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award allocation date, and update that information every 45 days thereafter. Condition During our testing over reporting for the student aid portion at Cypress College, we noted that the report required to be publicly available 30 days following the award becoming available was late by 36 days and therefore, the District did not meet the timeliness requirement. Cause Changing award program guidance/documentation, focused efforts on quick distribution of funds to students, remote work environment challenges, and a transition to a new website delayed initial posting of required reports. Effect The College?s 30 day report was uploaded to their website 36 days late. Questioned Costs None reported Context/Sampling The District has two colleges that were required to report student grant metrics and other data within 30 days of their award allocation date. Both reports were reviewed for compliance, with one report not submitted in a timely manner. Repeat Finding from Prior Year No Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures in place to ensure requirements and deadlines are met. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines. Management?s Response Upon receipt of funds, the Cypress College was immediately challenged with the urgency of creating distribution methodologies with vague award program guidance and documentation. The immediate rush to get funds to needy students, as quickly as possible, coupled with website content coordination issues due to a remote work environment as well as transition to a new campus website, caused the delayed posting of the initial required report. After the initial reporting, the information was updated as required until all funds were exhausted. For the Institutional portion, Cypress College was also late in submitting the first quarter?s report, which was due to be submitted by October 10, 2020 and was submitted on January 20, 2021, due to misinterpretation of the required submission process. Cypress College has improved documentation and understanding of award requirements and has implemented internal controls, including assigned personnel for report coordination and improved remote work environment coordination for website content, to ensure timely submission and posting of required reports.