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El Camino Community College DistrictHigher Education

EIN: 956001060

UEI: FN1HX3UK9SX1

Audited by: CliftonLarsonAllen LLP

Oversight agency: 84 [Department of Education]

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Data as of August 31, 2026

El Camino Community College District10 audit years11 findings4 repeat
10
Audit Years
11
Total Findings
4
Repeat Findings
$46.3M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$46,286,669 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 3, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 3, 2026 (1 day from today).

What is a management decision? →
2025-003
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2024-001OTHER MATTERS

It was noted during our testing of R2T4 calculations that 13 of 60 students selected for R2T4 testing had an instance of non-compliance due to Title IV funds not being returned within the 45 day time limit. Questioned Costs: None. Context: During our audit procedures, we noted 13 of the 60 students selected for R2T4 testing had Title IV funds not returned within the 45-day time limit. Cause: During fiscal year 2025, the District implemented additional procedures to strengthen the R2T4 process in response to the fiscal year 2024 audit finding. Because the 2024 audit report was issued after certain R2T4 calculations had already been completed, the newly implemented procedures resulted in corrections to some previously finalized calculations. 4 of the 13 instances of non‑compliance were attributable to these post‑implementation corrections. The remaining 9 instances of non‑compliance resulted from human error. Effect: The District did not return Title IV funds within the required time period. Repeat Finding: Yes, 2024-001. Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Views of Responsible Officials: Management concurs with the finding.

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Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan 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 grant or loan assistance that the student earned as of the student’s withdrawal date. In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. An institution does not satisfy this requirement if— (i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance. Condition: It was noted during our testing of R2T4 calculations that 13 of 60 students selected for R2T4 testing had an instance of non-compliance due to Title IV funds not being returned within the 45 day time limit. Questioned Costs: None. Context: During our audit procedures, we noted 13 of the 60 students selected for R2T4 testing had Title IV funds not returned within the 45-day time limit. Cause: During fiscal year 2025, the District implemented additional procedures to strengthen the R2T4 process in response to the fiscal year 2024 audit finding. Because the 2024 audit report was issued after certain R2T4 calculations had already been completed, the newly implemented procedures resulted in corrections to some previously finalized calculations. 4 of the 13 instances of non‑compliance were attributable to these post‑implementation corrections. The remaining 9 instances of non‑compliance resulted from human error. Effect: The District did not return Title IV funds within the required time period. Repeat Finding: Yes, 2024-001. Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District continue to enhance and consistently apply R2T4 procedures by providing ongoing training to staff responsible for R2T4 calculations and by continuing with additional reviews and quality control measures to ensure accuracy and compliance. Action taken in response to finding: The District acknowledges the importance of compliance with Return to Title IV (R2T4) requirements. The repeat finding cited in the subsequent audit relates to files processed prior to implementation of the corrective action plan. Since implementation, the District has not identified any new R2T4 errors or compliance issues. Action taken in response to finding: 1. Prior-Year File Remediation • Recalculated R2T4 amounts for affected students. • Returned required funds to the U.S. Department of Education. 2. Oversight and Review Controls • Engaged a NASFAA-certified consultant to review all R2T4 calculations during the 2024–2025 aid year. • Implemented secondary internal review of all R2T4 calculations. 3. Training and Staffing Enhancements • Completed department-wide and R2T4-specific training. • R2T4 staff completed NASFAA R2T4 course series. • An additional Accounting Officer position was added to support R2T4 processing and reconciliation with appropriate system access. 4. Process Improvements • Transitioned to the Department of Education’s R2T4 worksheet in COD. • Established formal coordination with Academic Affairs and the Registrar. • Updated R2T4 training and job aids. 5. Ongoing Monitoring • Management performs periodic internal reviews of R2T4 files. • The District continues to evaluate system and reporting enhancements. Conclusion Although the audit included R2T4 files processed prior to corrective action implementation, the District’s actions have been effective. No new R2T4 issues have been identified since implementation, and controls are in place to ensure ongoing compliance. Name of the contact person responsible for corrective action: David Brown, Acting Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 30, 2026

Prior Finding References

2024-001

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2025-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2024-002OTHER MATTERS

During our testing of 40 students, which is a statistically valid sample, we noted two instances of late reporting of student status changes. Questioned Costs: None. Context: During our audit procedures, we noted two instances of noncompliance. Cause: The District's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, 2024-002. Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Management concurs with the finding.

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Criteria: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted two instances of late reporting of student status changes. Questioned Costs: None. Context: During our audit procedures, we noted two instances of noncompliance. Cause: The District's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: Yes, 2024-002. Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: During the 2024-2025 audit, two enrollment records were reported late to NSLDS in October 2024. The late reporting occurred prior to the implementation of the corrective action plan developed during the 2023–2024 audit period. The previously identified cause was timing gaps between Clearinghouse file submission and NSLDS processing. Corrective Action Taken: The corrective action plan from the 2023–2024 audit period was fully implemented as of Spring 2025 and has addressed the root cause of the late reporting. Actions implemented include: • Reviewed and documented enrollment reporting timelines from Clearinghouse submission through NSLDS posting. • Established consistent file submission schedules aligned with NSLDS reporting deadlines. • Formalized communication and escalation procedures with the Clearinghouse and NSLDS, including designated points of contact. • Updated internal policies and procedures to reflect revised reporting timelines. • Provided training to staff responsible for enrollment reporting, emphasizing timeliness and compliance requirements. • Implemented monitoring controls to track file submission, acceptance, and processing by NSLDS. The 2023-2024 audit corrective action plan was successfully implemented in Spring 2025. Since implementation, no additional late enrollment reporting instances have occurred. Moving forward, it is expected that enrollment reporting to NSLDS will be timely and compliant with federal requirements, supported by documented procedures and ongoing monitoring controls. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2026

Prior Finding References

2024-002

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FY 2024-06-30

$36,911,645 federal awards expended

FAC accepted this audit on February 28, 2025 — management decision was due August 28, 2025.

2024-001
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2023-001

It was noted during our testing of R2T4 calculations that 17 of 40 students selected for R2T4 testing had an instance of non-compliance. Specifically, 12 students had excess returns totaling $2,404; one of those students also should have received a post-withdrawal disbursement of $124; three students had under returns of $22; and one student's return was not received within the 45-day time limit. Questioned Costs: Excess returns exceeded under returns and missed post-withdrawal disbursement. Accordingly, there are not net questioned costs. Context: During our audit procedures, we noted below instances for R2T4 testing: - 1 of the 40 total students' Pell was not returned within the 45 days requirement due to human error. - 16 of the 40 total students' R2T4 was incorrectly calculated. Cause: The District does not have proper second review in place to ensure student awards are properly adjusted based on calculations performed. Effect: The District is not returning the proper amounts to the Department based on the calculations performed. Repeat Finding: Yes, 2023-001. Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Views of Responsible Officials: Management concurs with the finding.

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2024 – 001: Return of Title IV Funds Testing Federal Agency: Department of Education Federal Program: Student Federal Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan 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 grant or loan assistance that the student earned as of the student’s withdrawal date. In accordance with 34 CFR 668.22(b) and (d)(4),the institution must return those funds for which it is responsible under paragraph (a) of this section to the respective title IV, HEA program as soon as possible, but no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. An institution does not satisfy this requirement if— (i) The institution's records show that the check was issued more than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 45 days after the date that the institution becomes aware that the student will not or has not begun attendance. Condition: It was noted during our testing of R2T4 calculations that 17 of 40 students selected for R2T4 testing had an instance of non-compliance. Specifically, 12 students had excess returns totaling $2,404; one of those students also should have received a post-withdrawal disbursement of $124; three students had under returns of $22; and one student's return was not received within the 45-day time limit. Questioned Costs: Excess returns exceeded under returns and missed post-withdrawal disbursement. Accordingly, there are not net questioned costs. Context: During our audit procedures, we noted below instances for R2T4 testing: - 1 of the 40 total students' Pell was not returned within the 45 days requirement due to human error. - 16 of the 40 total students' R2T4 was incorrectly calculated. Cause: The District does not have proper second review in place to ensure student awards are properly adjusted based on calculations performed. Effect: The District is not returning the proper amounts to the Department based on the calculations performed. Repeat Finding: Yes, 2023-001. Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

Prior Finding References

2023-001

About Special Tests and Provisions →
2024-002
Special Tests & Provisions
MATERIAL WEAKNESS

During our testing of 40 students, which is a statistically valid sample, we noted nine instances of late reporting of student status changes. Questioned Costs: None. Context: During our audit procedures, we noted nine instances of noncompliance. Cause: The District's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No. Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Management concurs with the finding.

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2024 – 002: NSLDS Enrollment Reporting Federal Agency: Department of Education Federal Program: Student Federal Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Noncompliance Criteria: In accordance with 34 CFR 685.309(b) and the National Student Loan Data System (NSLDS) Enrollment Reporting Guide published by the Department of Education, schools 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. In addition, schools must report enrollment status changes within 30 days of becoming aware of the status change or in its next scheduled enrollment submission if the scheduled submission is within 60 days. Condition: During our testing of 40 students, which is a statistically valid sample, we noted nine instances of late reporting of student status changes. Questioned Costs: None. Context: During our audit procedures, we noted nine instances of noncompliance. Cause: The District's internal controls did not identify the errors for compliance with the criteria mentioned above. Effect: Inaccurate information is reflected on the NSLDS database. A student’s enrollment data protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data, ensures loan repayment dates are accurately based on the last data of attendance, allows in-school deferments to be automatically granted using NSLDS enrollment data, and provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data. Repeat Finding: No. Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Views of Responsible Officials: Management concurs with the finding.

Corrective Action Plan

Recommendation: We recommend the District review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District has taken the following actions to address this recommendation: Assess Current Reporting Delays  Review the current submission schedule and identify specific time gaps between when Clearinghouse files are sent and when the data reaches NSLDS.  Work with the Clearinghouse to confirm file submission dates and compare them with NSLDS report uploads.  Document delays and establish a baseline for necessary improvements. Action 1.2: Communicate with NSLDS and Clearinghouse  Contact NSLDS and Clearinghouse support teams to communicate the delays and request any assistance or expedited processes.  Set clear expectations with these parties on how to resolve the reporting issue and prevent future delayed submissions. Establish Clear Reporting Timelines  Work with Clearinghouse to establish a clear, consistent timeline for file submission and confirm the timing of data submission to NSLDS.  Ensure reporting timelines align with NSLDS deadlines to ensure timely reporting.  Update internal policies and procedures to reflect the new reporting timeline and expectations. Staff Training and Awareness  Conduct training sessions for staff involved in the Clearinghouse file preparation and submission process, emphasizing the importance of timely submissions.  Provide regular updates and reminders about deadlines and processes. Automate or Enhance File Submission Process  Implement any necessary technology upgrades to streamline the data submission process.  Explore the possibility of setting up automatic file uploads directly to NSLDS to minimize delays. Implement Monitoring and Reporting System  Set up a monitoring system to track Clearinghouse file submissions to NSLDS, including confirmation that files have been successfully submitted and processed.  After implementing process changes, conduct monthly reviews to verify that student data is being submitted to NSLDS on time.  Track and report submission times Continuous Communication with NSLDS and Clearinghouse  Establish a point of contact at both NSLDS and the Clearinghouse to improve communication regarding file submission issues. Conduct regular reviews to ensure that the institutions’ reporting process aligns with NSLDS requirements. Name of the contact person responsible for corrective action: Dr. Kristina Martinez, Acting Dean of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

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FY 2023-06-30

$54,472,317 federal awards expended

FAC accepted this audit on March 13, 2024 — management decision was due September 13, 2024.

2023-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2022-002

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 40 samples tested, which is a statistically valid sample. 2) The return of funds was not properly calculated by the District. This was noted for 1 out of 40 samples, which is a statistically valid sample. Questioned Costs: None Context: The District disbursed $31,686,355 in Title IV awards during fiscal year 2022-23. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IVregulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: Yes, 2022-002. Recommendation: We recommend that the District 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: Management agrees with the finding and has developed a plan to correct the finding.

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2023 – 001: Return to Title IV Federal Agency: Department of Education Federal Program: Student Federal Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance 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, 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 40 samples tested, which is a statistically valid sample. 2) The return of funds was not properly calculated by the District. This was noted for 1 out of 40 samples, which is a statistically valid sample. Questioned Costs: None Context: The District disbursed $31,686,355 in Title IV awards during fiscal year 2022-23. Cause: The Districts’ internal controls did not ensure compliance with the applicable Title IVregulations. Effect: The cause identified resulted in noncompliance with Title IV regulations. Repeat Finding: Yes, 2022-002. Recommendation: We recommend that the District 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: Management agrees with the finding and has developed a plan to correct the finding.

Corrective Action Plan

2023-001: Student Financial Aid Cluster - Return to Title V 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. Action taken in response to finding: The Financial Aid office is implementing the following steps to ensure all Return to Title IV calculations are properly completed: To improve our process, a Return of Funds Calculation report is in place to assist with monitoring the return of unearned aid the Department of Education within 45 days of determination. An additional staff member has been assigned to the Return of Title IV program. We now have two staff members processing Return to Title IV calculations and each will be required to complete R2T4 training on an annual basis. The first staff member is assigned with the review of Return to Title IV calculations, while the second will conduct a secondary review for any miscalculation or data entry error. Thus, each Return to Title IV calculation will be checked by two staff members for accuracy. We will have an additional staff member help with the return of funds to COD to meet the 45-day rule; this will be on the accounting side. Our final step includes management review of Return to Title IV calculations. These added redundancy review will confirm Return to Title IV calculations are accurate. Our Return to Title IV procedures have been updated to reflect these changes. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: June 2024

Prior Finding References

2022-002

About Special Tests and Provisions →

FY 2022-06-30

$63,216,756 federal awards expended

FAC accepted this audit on March 2, 2023 — management decision was due September 2, 2023.

2022-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

Two out of 40 students selected for testing, in our statistically valid sample, did not receiveexit counseling within the required timeframe prescribed by the Department of Education.Questioned Costs: None.Context: The College disbursed $1,316,928 in Federal Direct Student Loan Program during the fiscalyear.Cause: The College?s? internal controls did not ensure compliance with the applicable Title IVregulations.Effect: Students are not receiving the proper loan counseling which may contribute to a higher defaultrate.Repeat Finding: This was not a finding in the prior year.Recommendation: We recommend the college review its policies and procedures around disbursingexit counseling information to students to ensure students are receiving proper counseling and ensureentrance counseling is documented before loans disbursements are made.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

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2022 ? 001: Student Eligibility and Awarding: Exit CounselingFederal Agency: Department of EducationFederal Program: Student Federal Assistance Cluster- Direct LoansAssistance Listing Number: 84.268Award Period: July 1, 2021 to June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and NoncomplianceCriteria: The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performedbefore disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan andDirect PLUS Loan to a graduate or professional student . The regulations also require exit counselingfor all students who ceases at least half-time study at the school.Condition: Two out of 40 students selected for testing, in our statistically valid sample, did not receiveexit counseling within the required timeframe prescribed by the Department of Education.Questioned Costs: None.Context: The College disbursed $1,316,928 in Federal Direct Student Loan Program during the fiscalyear.Cause: The College?s? internal controls did not ensure compliance with the applicable Title IVregulations.Effect: Students are not receiving the proper loan counseling which may contribute to a higher defaultrate.Repeat Finding: This was not a finding in the prior year.Recommendation: We recommend the college review its policies and procedures around disbursingexit counseling information to students to ensure students are receiving proper counseling and ensureentrance counseling is documented before loans disbursements are made.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

Corrective Action Plan

2022 ? 001: Student Financial Aid Cluster - Student Eligibility and Awarding: Exit Counseling ?Program Number 84.268Recommendation: We recommend the college review its policies and procedures around disbursingexit counseling information to students to ensure students are receiving proper counseling and ensureentrance counseling is documented before loans disbursements are made.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Financial Aid Office recognized that the exit loan counselingrule was not being met prior to the commencement of the 2021-2022 audit. The following action planwas already taking shape during the annual audit of 2021-2022 to ensure compliance rule would bemet for the 2022-2023 aid year.Process: Use SIS Colleague system to run query to identify current loan borrowers at beginning andend of term to identify those who have ceased half-time enrollment. Send communication via email andphysical letter notification to ensure student receive important information about loan repaymentresponsibilities, including Department of Education links and contact information.Procedure: Created documentation with step by step procedures for assigned staff to run query toidentify students, request exit loan counseling communication, and run batch posting of communication.Communication: Loan borrowers will receive an email on Day 1 run, a second email on Day 14 run, anda paper letter on Day 30 run.Staff Training: Staff assigned to the Loan program have been trained to run process by ourSystems/Programmer. Financial Aid Staff have been provided information about policy and proceduresto assist students who may contact our office for assistance after receiving exit loan counselingcommunication.Quality Assurance: Two additional staff members have been assigned to help with the Loan program.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: November 2022.

About Special Tests and Provisions →
2022-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The audit identified the following conditions:1) The institutional portion of unearned aid was not returned to the Department of Education within 45days. This was noted for 3 out of 40 samples tested, 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 40samples, which is a statistically valid sample.Questioned Costs: NoneContext: The District disbursed $26,553,987 in Title IV awards during fiscal year 2021-22.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 was not a finding in the prior year.Recommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. We also recommend an additional level of reviewis added in the process to ensure completed Return to Title IV calculations are properly completed.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

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2022 ? 002: Return to Title VFederal Agency: Department of EducationFederal Program: Student Federal Assistance ClusterAssistance Listing Number: VariousAward Period: July 1, 2021 to June 30, 2022Type of Finding: Significant Deficiency in Internal Control over Compliance and NoncomplianceCriteria: According to 34 CFR Section 668.173 (b), the institutional portion of unearned aid must bereturned to the appropriate Title IV, HEA program or Federal Family Education Loan (?FFEL?) lender nolater 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 thestudent earned as of the student?s withdrawal date. The Compliance Supplement issued by the Officeof Management and Budget requires auditors to review the return of Title IV fundsdeterminations/calculations for conformity with Title IV requirements. Furthermore, according to 34 CFR668.22, all grant funds relating to post-withdrawal disbursements that are not disbursed to the student?saccount, must be disbursed to the student no later than 180 days after the date of the institution?sdetermination 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 45days. This was noted for 3 out of 40 samples tested, 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 40samples, which is a statistically valid sample.Questioned Costs: NoneContext: The District disbursed $26,553,987 in Title IV awards during fiscal year 2021-22.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 was not a finding in the prior year.Recommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. We also recommend an additional level of reviewis added in the process to ensure completed Return to Title IV calculations are properly completed.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

Corrective Action Plan

2022 ? 002: Student Financial Aid Cluster - Return to Title V Exit Counseling ? Program NumberVariousRecommendation: We recommend that the Colleges improve the existing procedures and controls toensure compliance with the aforementioned criteria. We also recommend an additional level of reviewis added in the process to ensure completed Return to Title IV calculations are properly completed.Action taken in response to finding: The Financial Aid office is implementing the following steps toensure all R2T4 rules are met.Process: Create new report to monitor return of unearned aid to ED within 45 days of determination.Training: Staff involved with R2T4 processing will be provided time to undergo annual training by ED orNASFAA to ensure understanding of rules and regulations. Trainings by ED and NASFAA includepractice case studies to ensure correct application of R2T4 regulations.Quality Assurance: Two additional staff members have been assigned to help with R2T4 processing.One member to assist with the review of R2T4 calculations with the second staff member to help withthe return of aid on the accounting side. Also added to our R2T4 procedures, is management review ofR2T4 calculations per term.Name(s) of the contact person(s) responsible for corrective action: Chau Dao - Director ofFinancial AidPlanned completion date for corrective action plan: December 2023.

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2022-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The support for one student from a statistically valid sample 40 students could not belocated to perform required audit steps.Questioned Costs: NoneContext: The District disbursed $26,553,987in Title IV awards during fiscal year 2021-22.Cause: The College?s processes and controls did not ensure that student status changes were properlyand timely reported to NSLDS for all students.Effect: The case identified resulted in noncompliance with the Title IV regulation.Repeat Finding: This was not a finding in the prior year.Recommendation: We recommend that each College review their existing procedures and controlsand identify necessary changes needed to ensure timely reporting of student status changes to NSLDSas required by regulations.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

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2022 ? 003: Student Financial Aid Cluster: Enrollment Reporting ? VariousFederal Agency: Department of EducationFederal Program: Student Financial Aid ClusterAssistance Listing Number: VariousAward Period: July 1, 2021 through June 30, 2022Type of Finding: Significant Deficiency in Internal Control Over Compliance; NoncomplianceCriteria: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have somearrangement to report student enrollment data to National Student Loan Database Student (NSLDS)through an enrollment roster file. The school is required to report changes in the student?s enrollmentstatus, the effective date of the status, and an anticipated completion date. Also, the Code of FederalRegulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of allstudents regardless if they receive aid from the institution or not. Changes to said status are required tobe reported within 30 days of becoming aware of the status change, or with the next scheduledtransmission of statuses if the scheduled transmission is within 60 days. Regulations require the statusinclude an accurate effective date. There are two categories of enrollment information ?Campus Level?and ?Program Level? both of which need to be reported accurately. Regulations require the statusinclude an accurate effective date. In addition, regulations require that an institution return theenrollment rosters within 15 days from receipt of the rosters and make necessary corrections andresubmit to NSLDS within 10 days.Condition: The support for one student from a statistically valid sample 40 students could not belocated to perform required audit steps.Questioned Costs: NoneContext: The District disbursed $26,553,987in Title IV awards during fiscal year 2021-22.Cause: The College?s processes and controls did not ensure that student status changes were properlyand timely reported to NSLDS for all students.Effect: The case identified resulted in noncompliance with the Title IV regulation.Repeat Finding: This was not a finding in the prior year.Recommendation: We recommend that each College review their existing procedures and controlsand identify necessary changes needed to ensure timely reporting of student status changes to NSLDSas required by regulations.Views of Responsible Officials and Planned Corrective Actions: Please refer to the attachedCorrective Action Plan.

Corrective Action Plan

2022 ? 003: Student Financial Aid Cluster: Enrollment Reporting ? VariousRecommendation: Evaluate the current processes and possible backup controls to ensure errors arecaught in a timely manner.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: El Camino College will review the Enrollment VerificationProcess to ensure it is capturing all student enrollments and reporting them properly to NationalStudent Clearinghouse. The Departments involved Information Technology, Admissions & Recordsand Financial Aid will review how the data is collected from the college?s student information system(Ellucian Colleague) and the submissions to the National Student Clearinghouse and The NationalStudent Loan Data System to ensure the records are correct and submitted in a timely fashion.Name(s) of the contact person(s) responsible for corrective action: Lillian Justice, RegistrarPlanned completion date for corrective action plan: Immediate review of the data collection processwith the Information Technology Department and Financial Aid to ensure it is capturing all currentlyenrolled students. This will be an ongoing review beginning February 2023 to ensure we are capturingthe correct data.

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FY 2021-06-30

$51,683,973 federal awards expended

FAC accepted this audit on August 18, 2022 — management decision was due February 18, 2023.

2021-003
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

2021-003 Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Portion; COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Number: 84.425E, 84.425F Federal Agency: U.S. Department of Education Direct Funded by the U.S. Department of Education Criteria or Specific Requirement Material Weakness in Internal Control and Noncompliance - Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student and Institutional Aid Portion awards to publicly post the HEERF quarterly reports 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 student and institutional aid portion awards, we noted the following: 1. The Student Portion report for the quarter ending June 30, 2021 was not prepared or posted to the District?s website. 2. The Institutional Portion reports for the quarters ending March 31, 2021 and June 30, 2021 were not prepared or posted to the District?s website. 3. The District did not maintain supporting documentation to verify the amounts reported for the Institutional Reports posted for the quarters ending September 30, 2020 or December 31, 2020. Questioned Costs None reported. Context The District is 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. The auditor reviewed whether Student Portion and Institutional Portion reports were prepared for all quarters during the year ending June 30, 2021. Effect The District?s quarterly reports were not uploaded to their website. Additionally, the information contained in the reports that were uploaded to their website could not be verified against relevant supporting documentation. Cause The District did not have a procedure in place to ensure reports were completed in the appropriate timeframe in spite of changes in staffing. Additionally, the District did not adhere to documentation retention policies for the reports completed. Repeat Finding: 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.

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2021-003 Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Student Portion; COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Number: 84.425E, 84.425F Federal Agency: U.S. Department of Education Direct Funded by the U.S. Department of Education Criteria or Specific Requirement Material Weakness in Internal Control and Noncompliance - Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Student and Institutional Aid Portion awards to publicly post the HEERF quarterly reports 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 student and institutional aid portion awards, we noted the following: 1. The Student Portion report for the quarter ending June 30, 2021 was not prepared or posted to the District?s website. 2. The Institutional Portion reports for the quarters ending March 31, 2021 and June 30, 2021 were not prepared or posted to the District?s website. 3. The District did not maintain supporting documentation to verify the amounts reported for the Institutional Reports posted for the quarters ending September 30, 2020 or December 31, 2020. Questioned Costs None reported. Context The District is 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. The auditor reviewed whether Student Portion and Institutional Portion reports were prepared for all quarters during the year ending June 30, 2021. Effect The District?s quarterly reports were not uploaded to their website. Additionally, the information contained in the reports that were uploaded to their website could not be verified against relevant supporting documentation. Cause The District did not have a procedure in place to ensure reports were completed in the appropriate timeframe in spite of changes in staffing. Additionally, the District did not adhere to documentation retention policies for the reports completed. Repeat Finding: 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.

Corrective Action Plan

View of Responsible Officials and Corrective Action Plan The District had experienced turnover in key positions responsible for submission of HEERF reports at the conclusion of the 2020-2021 fiscal year. All HEERF reporting has been brought current during the 2021-2022 fiscal year. Staff has reporting deadlines set in their calendars and all reports are reviewed by the business manager and executive management prior to placement on the District website as well as submission to the U.S. Department of Education. Reporting will be overseen by the business manager to ensure timely and accurate adherence to reporting requirements.

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FY 2020-06-30

$39,676,066 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 17, 2021 — management decision was due September 17, 2021.

FY 2019-06-30

$39,952,407 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 9, 2020 — management decision was due July 9, 2020.

FY 2018-06-30

LOW-RISK AUDITEE$42,112,688 federal awards expended

FAC accepted this audit on December 19, 2018 — management decision was due June 19, 2019.

2018-001
Matching, Level of Effort, Earmarking
MODIFIED OPINIONSIGNIFICANT DEFICIENCYQUESTIONED COSTS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-06-30

LOW-RISK AUDITEE$41,715,310 federal awards expended

FAC accepted this audit on January 9, 2018 — management decision was due July 9, 2018.

2017-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-06-30

LOW-RISK AUDITEE$43,249,188 federal awards expendedNo findings recorded this year

FAC accepted this audit on January 3, 2017 — management decision was due July 3, 2017.

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