SAN DIEGO COMMUNITY COLLEGE DISTRICT

Special Tests and Provisions – Return of Title IV Funds Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct funded by the U.S. Department of Education (ED) Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Award Identification Number: P007A230565, P007A240565, P007A240568, P007A244666, P033A230565, P033A230568, P033A234666, P033A240565, P033A240568, P033A244666, P063P230042, P063P230043, P063P230636, P063P240042, P063P240043, P063P240636, P268K240042, P268K240043, P268K240636, P268K250042, P268K250043, P268K250636 Award Year: 2024-2025 Criteria 34 CFR 668.22(a), 34 CFR 668.22(e), and 34 CFR 668.22(f) When a recipient of Title IV 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 aid earned by the student as of the student’s withdrawal date. The amount of Title IV assistance that is earned by the student is calculated by determining the percentage of aid earned by the student and applying the percentage to the total amount of Title IV assistance that was disbursed and that could have been disbursed to the student. 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. For programs measured in credit hours, the percentage of aid earned by the student is determined by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – The following deficiencies were noted:  1 of 60 students’ Return of Title IV calculation was calculated incorrectly for Miramar College (the College did not exclude the scheduled breaks from the total number of calendar days in the payment period or period of enrollment).  1 of 60 students’ Return of Title IV calculation was calculated incorrectly for Mesa College (the College excluded scheduled breaks from the total number of calendar days in the payment period or period of enrollment when the courses in the program were offered in modules and did not have scheduled breaks of at least five consecutive days).  1 of 60 students’ Return of Title IV funds was returned in the incorrect amount for Mesa College (the College had a transposition error in the institution’s required amount to return). Questioned Costs There are no questioned costs associated with the condition identified. Context There were approximately 1,527 Return of Title IV calculations performed during the year ended June 30, 2025. Effect The District is not in compliance with the Federal Return of Title IV requirements described in the OMB Compliance Supplement. Cause The District’s internal controls were not adequately designed to prevent erroneous information utilized in the calculations and to ensure funds are returned accurately. Repeat Finding (Yes or No) No. Recommendation The District should strengthen internal controls over the review of Return of Title IV calculations to ensure that calculations and funds returned are accurate.

Special Tests and Provisions – Enrollment Reporting Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded by the U.S. Department of Education (ED) Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Award Identification Number: P007A230565, P007A240565, P007A240568, P007A244666, P033A230565, P033A230568, P033A234666, P033A240565, P033A240568, P033A244666, P063P230042, P063P230043, P063P230636, P063P240042, P063P240043, P063P240636, P268K240042, P268K240043, P268K240636, P268K250042, P268K250043, P268K250636 Award Year: 2024-2025 Criteria OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance and Noncompliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: • 27 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). • 16 students from City College • 9 students from Mesa College • 2 students from Miramar College • 6 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). • 4 students from City College • 2 students from Mesa College Questioned Costs There are no questioned costs associated with the condition identified. Context The District disbursed financial aid to approximately 14,730 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. • For the students with dates of change not agreeing to the effective dates. • The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. • For the students with enrollment status not accurately reported, there was an error in reporting the enrollment status after the student had dropped all their classes for term. Repeat Finding (Yes or No) Yes, see 2024-003 in the Summary Schedule of Prior Audit Findings. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Criteria or Specific Requirements The Uniform Guidance states that allowable personnel costs charged to federal programs may include reasonable amounts for activities contributing and directly related to work under an agreement (2 CFR 200.430(i)(1)(i)). Charges to federal awards for salaries and wages must be based on records that accurate reflect the work performed (2 CFR 200.430(g)(1)). Condition Material Weakness in Internal Control over Compliance – Time-and-effort reporting, or another similar internal control activity to retroactively verify employee time spent on the program was not reviewed and approved or not performed for the year ending June 30, 2024. During testing over Activities Allowed or Unallowed and Allowable Cost requirements, the following deficiencies were noted:  For the Career and Technical Education program, 14 out of 14 employees selected for testing do not have time-and-effort record reflecting the distribution of the employee’s salary and wages for the federal program.  For the Title III and V programs, we noted the following – o 25 out of 30 employees selected for testing did not have time-and-effort record reflecting the distribution of the employee’s salary and wages for the federal program. o 5 out of 30 employees selected for testing had time-and-effort records, however, there were no evidence of review and approval. 2 of the 5 employees also had incomplete time-and-effort reports (i.e. only for half of the fiscal year, or a few months). Questioned Costs Career Technical Education – Basic Grants to States known questioned costs: $749,547. Higher Education Institutional Aid programs known questioned costs: $1,431,770. Context The Career Technical Education program reference above had a total of $2,355,332 in expenditures for the year ended June 30, 2024, of which $1,108,453 were associated with salaries and benefits. There was a total population of 66 employees charged to the program in the fiscal year ended June 30, 2024. The Title III and V programs referenced above had a total of $2,865,454 in expenditures for the year ended June 30, 2024, of which $2,248,191 associated with salaries and benefits. There was a total population of 148 employees charged to the program in the fiscal year ended June 30, 2024. Effect Without effective internal controls in place over personnel costs, the District risks noncompliance for program costs that could be material. Cause The District does not have policies and procedures in place to review personnel charges to identify the employee costs that should and should not be charged to the federal program referenced above. Repeat Finding (Yes or No) No Recommendation The District should monitor personnel costs charged to federal programs in accordance with the Uniform Guidance. The District should review personnel costs on a regular basis to ensure that costs charged are supported by allowable activities directly related to the program. Additionally, adequate supporting documentation should be retained for personnel costs charged to the federal programs. Views of Responsible Officials and Corrective Action Plan The District and campus staff will work together to develop processes to capture proper and relevant time and effort activities. This will ensure documentation can be provided regarding personnel expenses to identify employee costs charged to federal programs.

Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – The following deficiencies were noted:  2 of 60 students’ effective dates were not accurately reported in NSLDS (status per student accounts do not agree to status per NSLDS) for Mesa College.  1 of 60 students’ change in enrollment status was not reported in NSLDS for Mesa College. Questioned Costs There are no questioned costs associated with the condition identified. Context We tested a nonstatistical sample of 60 students of the approximately 1,159 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS accurately. The reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. Repeat Finding (Yes or No) Yes. See item 2023-002 in the Summary Schedule of Prior Audit Findings. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website. View of Responsible Officials and Corrective Action Plan Processes will be implemented to review, update and verify data captured by NSLDS and ensure such data has been accurately reported in a timely manner.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268, and 84.408 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information: “Campus Level” and “Program Level”, both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements, the following deficiencies were noted: •1 of 60 students’ CIP code was not accurately reported (enrolled program in NSLDS does not agree with the student’s record) for Miramar College. •21 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). •4 students from City College •14 students from Mesa College •3 students from Miramar College •2 of 60 students’ enrollment statuses were not accurately reported on NSLDS (status per student accounts do not agree to status per NSLDS). •1 student from City College •1 student from Miramar College Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 9,462 students that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. •For the student with enrolled program inaccurately reported, the student’s program was tied to the wrong CIP code in the District system’s academic plan table. •For the students with dates of change not agreeing to the effective dates – o The District’s system automatically modified the withdrawal date to the beginning of the term for students who withdrew from all their classes. o Students with changes in April 2023 were done in batches and did not match with the actual dates of change in April 2023. •For the students with enrollment status not accurately reported, the reporting extract from Campus Solutions was not properly reviewed and corrected before transmitting to the National Clearing House. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Financial Assistance Listing Numbers: 84.425F Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. ED collected an annual report for HEERF grantees in March 2023 covering calendar year 2022 expenditures. On June 17, 2022, ED announced an updated format for the HEERF Quarterly Report effective for Q2 2022, report to be posted July 10, 2022. The quarterly portion reporting requirements involve publicly posting completed forms conspicuously on the institution’s website. Condition Significant Deficiency in Internal Control over Compliance - The quarters ended September 30, 2022 and December 31, 2022 quarterly public report were selected for testing. 5 of the 6 reports selected for testing were not made publicly available on the District’s website. Questioned Costs There are no questioned costs associated with this finding. Context The District has 3 colleges that were required to post forms covering the aggregate amounts spent for HEERF I, II, and III quarterly, as well as one annual report per college. Effect The quarterly reports were not publicly posted on the District’s website. In addition, the supporting documentation was not available for review. Cause The District did not have internal controls in place to ensure quarterly reports were made publicly available and completed accurately with sufficient supporting documentation. Recommendation The District should implement internal controls to ensure that reporting requirements and deadlines are clearly communicated to all staff.

Criteria or Specific Requirement: In accordance with 34 CFR 685.309 and 34 CFR 690.83, institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately. In addition, regulations require that an institution return the enrollment rosters within 15 days from receipt of the rosters and make necessary corrections and resubmit to NSLDS within 10 days. Furthermore, 2 CFR 200.303 requires non-Federal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student enrollment status changes are accurately and timely reported to the NSLDS. Condition: Although improvements were made and error rates decreased from the prior year, City College, Mesa College and Miramar College continued to have errors in reporting enrollment information. Questioned Costs: None Context: City College - Twenty students tested identified the following conditions: The enrollment effective date reported to NSLDS did not match the College?s record - 3 students. Mesa College - Twenty students tested identified the following conditions: The enrollment effective date reported to NSLDS did not match the College?s record - student . Program begin date did not match the College's record - 1 student. The student?s enrollment status was not reported timely to NSLDS - 1 students. The program enrollment effective date reported to NSLDS did not match the College's record ? 1 student. The student?s enrollment status was not reported to NSLDS - 1 student. Miramar College- Twenty students tested identified the following conditions: The student?s enrollment status was not reported timely to NSLDS - 1 students. The program enrollment effective date reported to NSLDS did not match the College's record ? student. The enrollment effective date reported to NSLDS did not match the College?s record ? 1 students. The College did not correct the errors of the rosters and resubmit to NSLDS within the 10-day requirement for Enrollment Reporting Summary Report (SCHER1). Cause: The Colleges? internal controls processes were being implemented during the year as a result of prior year finding and additional time was needed to completely implement. Effect: The NSLDS database did not include accurate information. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of Title IV. Repeat Finding: Similar conditions were noted in the prior year, see finding number 2021-003.

2021 ? 001: Activities Allowed or Unallowed, Allowable Cost/Cost PrinciplesFederal Agency: Department of EducationFederal Program Title: Higher Education Emergency Relief Fund (HEERF) Institutional Aid PortionAssistance Listing Number: 84.425FAward Period: July 1, 2020 to June 30, 2021Type of Finding: Significant Deficiency in Internal Control over Compliance and NoncomplianceCriteria or Specific Requirement: Institutions must demonstrate that costs incurred are allowableunder the relevant statutory provisions and consistent with the purpose of the ESF ?to prevent, preparefor, and respond to coronavirus.? In general, the CARES Act authorized broad uses of HEERF funds,with specific standards for the different subprograms. The CRRSAA expanded the allowable uses forsupplemental awards and new awards made under Section 314(a)(1) of the CRRSAA. The expandeduse of funds authority also applies to unexpended HEERF I funds as of December 27, 2020 (the date ofenactment of the CRRSAA).Condition: During our testing, we noted 1 transaction out of 40 transactions tested, was not allowable.Questioned Costs: NoneContext: The District expended $14,599,228 in HEERF Institutional Aid Portion during fiscal year 2021.Cause: The District?s internal controls did not ensure compliance with the requirements within thecriteria mentioned above.Effect: The cause identified resulted in noncompliance with the requirements within the criteriamentioned above.Repeat Finding: This is not a repeat finding.Recommendation: We recommend that the District improve the existing procedures and controls toensure compliance with the aforementioned criteria such as having an additional level of review bymanagements or an internal auditor. Also, we recommend the District improve the review process bymaintaining adequate documentation to support all charges to new and existing federal programs.Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2021 ? 002: Attendance in Distance Education for Return to Title IV StudentsFederal Agency: Department of EducationFederal Program Title: Student Federal Assistance ClusterAssistance Listing Number: VariousAward Period: July 1, 2020 to June 30, 2021Type of Finding: Significant Deficiency in Internal Control over Compliance and NoncomplianceCriteria or Specific Requirement: Title IV funds may be expended only towards the education of thestudents who can be proven to have been in attendance at the institution. In a distance educationcontext, documenting that a student has logged into an online distance education platform or system isnot sufficient, by itself, to demonstrate attendance by the student. To avoid returning all funds for astudent that did not begin attendance, an institution must be able to document ?attendance at anyclass.? To qualify as a last date of attendance for Return of Title IV purposes, an institution mustdemonstrate that a student participated in class or was otherwise engaged in an academically relatedactivity, such as by contributing to an online discussion or initiating contact with a faculty member to aska course-related question. An institution that is required to take attendance or requires that attendancebe taken on only one specified day to meet a census reporting requirement, is not considered to takeattendance (34 CFR 668.22(b)(3)).Condition: During our testing, we noted for 1 out of 14 Mesa College students and 1 out of 12 MiramarCollege students, who had received Federal Aid and had withdrawn from a distance education classand the College was not able to provide support of the student?s attendance and participation support.Questioned Costs: NoneContext: The District expended $36,295,122 in Title IV awards during fiscal year 2021.Cause: The Colleges? internal controls did not ensure compliance with the applicable Title IVregulations.Effect: The cause identified resulted in noncompliance with Title IV regulations.Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. And the Colleges need to maintain all the students?participation documentation in distance education classes to ensure accuracy of withdrawal date forReturn to Title IV calculation.Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2021 ? 003: Enrollment ReportingFederal Agency: Department of EducationFederal Program Title: Student Federal Assistance ClusterAssistance Listing Number: VariousAward Period: July 1, 2020 to June 30, 2021Type of Finding: Significant Deficiency in Internal Control over Compliance and NoncomplianceCriteria or Specific Requirement: In accordance with 34 CFR 685.309 and 34 CFR 690.83,institutions are required to report enrollment information under the Pell Grant and Direct Loan programsvia the National Student Loan Data System (NSLDS). The administration of the Title IV programsdepends heavily on the accuracy and timeliness of the enrollment information reported by institutions.Institutions must review, update, and verify student enrollment statuses, program information, andeffective dates. There are two categories of enrollment information; ?Campus Level? and ?ProgramLevel,? both of which need to be reported accurately.In addition, regulations require that an institution return the enrollment rosters within 15 days fromreceipt of the rosters and make necessary corrections and resubmit to NSLDS within 10 days.Furthermore, 2 CFR 200.303 requires non-Federal entities to, among other things, establish andmaintain effective internal control over the Federal award that provides reasonable assurance that thenon-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, andthe terms and conditions of the Federal award. Effective internal controls should include establishingprocedures to ensure student enrollment status changes are accurately and timely reported to theNSLDS.Condition: Although improvements were made and error rates had gone down from prior year audit,our audit procedures resulted in the following conditions by Colleges:City College - Twenty students tested identified the following conditions:1) The enrollment effective date reported to NSLDS did not match the College?s record - 3students.2) The College did not correct the errors of the rosters and resubmit to NSLDS within the 10-dayrequirement for Enrollment Reporting Summary Report (SCHER1).Mesa College - Twenty students tested identified the following conditions:1) The student?s enrollment status did not match the College?s Record - 1 student.2) The program enrollment effective date reported to NSLDS did not match the College's record - 2student.3) The enrollment eMiramar College- Twenty students tested identified the following conditions:1) Student received financial aid and was not reported to NSLDS - 1 student.2) Program begin date did not match the College's record - 1 student.3) The program enrollment effective date reported to NSLDS did not match the College's record - 2students.4) The enrollment effective date reported to NSLDS did not match the College?s record - 2students.Questioned Costs: NoneContext: The District expended $36,295,122 in Title IV awards during fiscal year 2021.Cause: The Colleges? internal controls processes were being implemented during the year as a resultof prior year finding and additional time were needed to completely implement.Effect: The NSLDS database did not include accurate information. A student?s enrollment statusdetermines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timelyand accurate manner is critical for effective management of Title IV.Repeat Finding: Similar conditions were noted in the prior year, see finding number 2020-003.Recommendation: We recommend that the Colleges continue to improve the existing procedures andcontrols to ensure timely and accurate reporting of student status to NSLDS as required by regulations.Views of Responsible Officials: Please refer to the attached Corrective Action Plan.ffective date reported to NSLDS did not match the College?s record - 3students.

2020 ? 002: Return of Funds on Behalf of Students Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster CFDA Number: Various Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: According to 34 CFR Section 668.173 (b), the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (?FFEL?) lender no later than 45 days after the date of the institution?s determination that the student withdrew. Furthermore, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. The Compliance Supplement issued by the Office of Management and Budget requires auditors to review the return of Title IV funds determinations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR 668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student?s account, must be disbursed to the student no later than 180 days after the date of the institution?s determination that the student withdrew. Condition: The audit identified the following conditions: 1) The institutional portion of unearned aid was not returned to the Department of Education within 45 days. This was noted for 1 out of 20 samples tested from San Diego City College and 1 out of 20 samples from San Diego Mesa College, which is a statistically valid sample. 2) The return of funds was not properly calculated by the College. This was noted for 2 out of 20 samples from San Diego City College, which is a statistically valid sample. 3) The post withdrawal disbursements for 2 out of 20 students tested at San Diego Mesa College were not made within the 180 day timeline, which is a statistically valid sample. Questioned Costs: None Context: The District disbursed $51,490,669 in Title IV awards during fiscal year 2020. Cause: The Colleges? internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: Similar conditions were noted in the prior year, see finding number 2019-001. Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure compliance with the aforementioned criteria. We also recommend an additional level of review is added in the process to ensure completed Return to Title IV calculations are properly completed. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 003: Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster CFDA Number: Various Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: In accordance with 34 CFR 685.309 and 34 CFR 690.83, institutions are required to report enrollment information under the Pell Grant and Direct Loan programs via the National Student Loan Data System (NSLDS). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately. Condition: The audit identified the following conditions: 1) The student?s enrollment status was not certified every 60 days. This condition was noted for 52 out of 60 samples tested, which is a statistically valid sample. 2) The student?s program enrollment effective date was not reported correctly to NSLDS. This condition was noted for 5 out of 60 students tested, which is a statistically valid sample. 3) The student?s enrollment status according to the transcripts was not reported correctly to NSLDS. This condition was noted for 4 out of 60 samples tested, which is a statistically valid sample. 4) The student?s change in enrollment status was not reported to NSLDS within the prescribed timeframe. This condition was noted for 2 out of 60 samples tested, which is a statistically valid sample. 5) The student?s enrollment effective date was not reported correctly to NSLDS. This condition was noted for 2 out of 60 students, which is a statistically valid sample. Questioned Costs: None Context: The District disbursed $51,490,669 in Title IV awards during the fiscal year. Cause: The Colleges? internal controls did not ensure compliance with the applicable Title IV regulations.Effect: The NSLDS database did not include accurate information. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of Title IV. Repeat Finding: Similar conditions were noted in the prior year, see finding number 2019-002. Recommendation: We recommend that the Colleges improve the existing procedures and controls to ensure timely and accurate reporting of student status to NSLDS as required by regulations. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 004: Direct Loan Reconciliations Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster- Direct Loans CFDA Number: 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires the Colleges, on a monthly basis, to reconcile the institutional records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary. Condition: The required monthly reconciliations were not performed at San Diego City College and San Diego Mesa College. Questioned Costs: None. Context: The District disbursed $2,672,440 in Direct Loans during the fiscal year. Cause: The Colleges? internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The Colleges are not complying with federal requirements to ensure Direct Loan funds are properly reconciled. Repeat Finding: Similar conditions were noted in the prior year, see finding number 2019-004. Recommendation: We recommend the Colleges establish procedures to ensure the proper reconciliations are performed on a timely basis. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 005: Verifications Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster- Pell CFDA Number: 84.063 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: The Federal Student Aid Handbook published by the Department of Education requires Institutions to report the verification status of Pell recipients through Common Origination and Disbursement (COD). Condition: San Diego Mesa College did not report the verification status of 1 out of 13 students that were selected for the audit, which is a statistically valid sample. Questioned Costs: None. Context: The College disbursed $16,889,663 in Federal Pell Grant Program during the fiscal year. Cause: The Colleges? internal controls did not ensure compliance with the applicable Title IV regulations. Effect: The Colleges did not comply with federal requirements to ensure verification status of Pell recipients are properly reported to COD. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the Colleges establish procedures to ensure verification status of the Pell recipients are properly reported. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

2020 ? 006: Exit Counseling Federal Agency: Department of Education Federal Program Title: Student Federal Assistance Cluster- Direct Loans CFDA Number: 84.268 Award Period: July 1, 2019 to June 30, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student . The regulations also require exit counseling for all students who ceases at least half-time study at the school. Condition: 4 out of 60 students selected for testing, in our statistically valid sample, did not receive exit counseling within the required timeframe prescribed by the Department of Education. This condition was noted for students attending San Diego City College. Questioned Costs: None. Context: The College disbursed $986,321 in Federal Direct Student Loan Program during the fiscal year. Cause: The College?s? internal controls did not ensure compliance with the applicable Title IV regulations. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat Finding: This was not a finding in the prior year. Recommendation: We recommend the college review its policies and procedures around disbursing exit counseling information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Views of Responsible Officials: Please refer to the attached Corrective Action Plan.

FINDING 2019-001 ? Special Tests and Provisions: Return of Funds on Behalf of the Students: Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: Various Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance Criteria: According to 34 CFR Section 668.173 (b), the institutional portion of unearned aid must be returned to the appropriate Title IV, HEA program or Federal Family Education Loan (?FFEL?) lender no later than 45 days after the date of the institution?s determination that the student withdrew. Furthermore, according to 34 CFR 668.22 (a)(6)(ii)(B)(1), all grant funds relating to post-withdrawal disbursements that are not disbursed to the student?s account, must be disbursed to the student no later than 45 days after the date of the institution?s determination that the student withdrew. Condition / Context: We selected a sample of 60, which is a statically valid sample of students who received Federal aid and had withdrawn from courses offered by the Colleges during the 2018-2019 fiscal year. During our testing we noted that 5 students from San Diego City College, 6 students from San Diego Miramar College, and 2 students from San Diego Mesa College, for a total of 13 students, had funds returned to the Department of Education after the 45 days of the date of the colleges? determination that the students withdrew. We also noted a total of 5 students, 2 students from San Diego City College, 1 student from San Diego Miramar College, and 2 students from San Diego Mesa College, had post-withdrawal disbursements for grant funds made after the 45 days of the date of the colleges? determination that the students withdrew. Questioned Costs: None. Cause: The colleges' internal controls did not ensure compliance with the criteria mentioned above. Effect: The cases identified resulted in non-compliance with the applicable Return to Title IV compliance requirements. Repeat Finding: There was not a finding in the prior year. Recommendation: The colleges should implement procedures and controls to ensure the refunds are returned on a timely basis. Views of responsible officials: There is no disagreement with audit finding.

Finding 2019-002: Special Tests and Provisions: Enrollment Reporting Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: Various Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance Criteria: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don?t pass the NSLDS enrollment reporting edits. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student enrollment status changes are accurately and timely reported to the NSLDS. Condition / Context: During our testing, we selected a sample of students to test for timeliness of reporting student status changes to the National Student Loan Data System (NSLDS). We noted discrepancies for 2 students from San Diego City College and 4 students from San Diego Mesa College, for a total of 6 students, where the students? enrollment status change was not reported to NSLDS on a timely basis. The colleges utilize the National Student Clearinghouse (NSC) as a third party provider in order to submit student information to NSLDS. However, it is possible for the Colleges to create an Enrollment Reporting Summary Report after reporting student status changes to NSLDS, which would have detected these types of errors. Questioned Costs: None. Cause: The District did not provide updated rosters to NSC on a timely basis. This resulted in a delay in submission of the student?s status change information to NSLDS. Effect: The NSLDS database did not include accurate information until the point at which it was correctly reported. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Repeat Finding: Similar finding noted in the prior year. See finding 2018-002. Recommendation: We recommend that the colleges improve the existing procedures and controls to ensure the timely reporting of student status changes to the NSLDS as required by regulations. Views of responsible officials: There is no disagreement with audit finding.

Finding 2019-003: Special Tests and Provisions: COD Reporting Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: Various Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance. Criteria: The Department of Education requires the Colleges to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition / Context: During our testing, we noted that 12 disbursements from San Diego City College, 10 disbursements from San Diego Miramar College, and 9 disbursements from San Diego Mesa College, for a total of 31 of the 100 Pell disbursements tested, were not reported within the required 15 days to the Common Origination and Disbursement (COD) system. Questioned Costs: None. Cause: The colleges? internal controls did not ensure compliance with the criteria mentioned above. Effect: Students interest accrues based on disbursement date reported to COD, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: There was not a finding in the prior year. Recommendation: We recommend the colleges evaluate their procedures and policies around reporting Pell and Direct Loan disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: There is no disagreement with audit finding.

Finding 2019-004: Special Tests and Provisions: Borrower Data Transmission and Reconciliation (Direct Loan) Federal agency: Department of Education Federal program title: Student Financial Aid Cluster CFDA Numbers: 84.268 ? Federal Direct Student Loans Award Period: July 1, 2018 through June 30, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Non-Compliance. Criteria: Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the Common Origination and Disbursement (COD) within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the District) Loan Detail records. The District is required to reconcile these files to the institution?s financial records. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include establishing procedures to ensure student enrollment status changes are accurately and timely reported to the National Student Loan Data System (NSLDS). Condition / Context: We were unable to obtain evidence that San Diego City College and San Diego Mesa College are performing the required direct loan reconciliations. Questioned Costs: None. Cause: The colleges' internal control process did not ensure the required reconciliations were completed. Effect: There could be unreconciled differences with DLSS. Repeat Finding: There was not a finding in the prior year. Recommendation: We recommend the colleges' establish procedures to ensure the proper reconciliations are performed on a timely basis. Views of responsible officials: There is no disagreement with audit finding.

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