MT. SAN ANTONIO COMMUNITY COLLEGE DISTRICT

Special Test and Provisions – Enrollment Reporting Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268 Award Identification Numbers: P007A240491, P033A240491, P063P241158, P268K251158 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 Instance of Noncompliance – During testing over the NSLDS reporting requirements, five of sixty students’ effective dates were not accurately reported in NSLDS (date of change does not agree to effective dates). Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of sixty students NSLDS reporting records. The District disbursed financial aid to approximately 12,657 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 District identified a technical issue related to extracting the correct enrollment effective date and, instead, reported the run date of the enrollment statuses. Repeat Finding (Yes or No) Yes. See prior year finding 2024-001. 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.

Views of Responsible Officials and Corrective Action Plan The discrepancies noted during the 2024–2025 Financial Aid Audit were found to be attributable to a separate system configuration issue, distinct from the discrepant records identified in the 2023–2024 annual audit, which involved incorrect reporting of effective enrollment status dates. To resolve this matter and prevent recurrence, the District has implemented the following corrective actions: 1. Root-Cause Analysis: Conducted a comprehensive review with IT, Admissions & Records, Financial Aid, and third-party consultants to isolate and correct the specific system errors. 2. Update Systems Settings: Updating systems settings to accurately select records for reporting along with the perspective effective date and accurately report the three-quarter time enrollment level. 3. Manual Verification: Financial Aid staff responsible for Return to Title IV (R2T4) processing will manually review all student enrollment records in NSLDS (approximately 2,400 annually) to ensure accuracy. 4. Ongoing Compliance Monitoring: Established quarterly joint compliance reviews with IT, Admissions and Financial Aid leadership to verify continued accuracy of NSC/NSLDS reporting and to ensure timely detection of anomalies.

2024-001

Special Test and Provisions – Return to Title IV Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Award Identification Numbers: P007A240491, P033A240491, P063P241158, P268K251158 Award Year: 2024-2025 Criteria 34 CFR section 668.173(b) Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance – Nine of the sixty Return to Title IV calculations were returned later than 45 days after the institution determined the student withdrew. Questioned Costs There are no questioned costs associated with this finding. All funds were returned, however, not within the 45-day requirement. Context We tested a non-statistical sample of sixty Return to Title IV calculations of a total of 683 calculations performed by the District during the year ended June 30, 2025. Effect Without proper monitoring of the timing of student withdrawals and calculations of Return to Title IV, the District risks noncompliance with the above referenced criteria. Cause The District’s internal controls did not have adequate internal controls and monitoring procedures in place to ensure timely identification and processing of Return of Title IV funds. This resulted in instances in which the return of funds was not completed within the required time frame. Repeat Finding (Yes or No) No. Recommendation The District should implement procedures and improve controls over the review of the calculations to ensure funds are returned in a timely manner.

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

Special Test and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.007, and 84.033 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, 29 of 60 students’ effective dates were not accurately reported in NSLDS (date of change do not agree to effective dates). Questioned Costs There are no questioned costs associated with the noncompliance. Context The District disbursed financial aid to approximately 1,449 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 District identified a technical issue related to extracting the correct enrollment effective date and, instead, reported the run date of the enrollment statuses. Repeat Finding (Yes or No) No. 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.

Federal Awards Findings And Recommendations 2024-001 Special Tests and Provisions - Enrollment Reporting View of Responsible Officials and Corrective Action Plan The Financial Aid and Admissions and Records departments in collaboration with the district, contracted with an outside consultant to help identify why the enrollment reporting process was not accurately reporting students' enrollment levels. It was identified that a system setting was not set to capture chnage sof enrollment levels within the specific terms. Based on the consultant recommendation, the district agreed to update system settings to accurately report student enrollment level changes throughout the term. These adjustments to the system settings will allow for the accurate and timely reporting of information to the National Student Loan Database System (NSLDS). This ongoing change to system settings is in place beginning with the Fall 2024 term. Additionally, the district has implemented internal controls to include: Developed additional training and Information Technology support structures to maintain data integrity associated with the National Student Clearinghouse (NSC) data submission, Developed pre data submission audit report to check for accuracy prior to the upload of required data to the NSC, and Created an internal work group consisting of financial aid and admissions and records professionals to review information associated with NSC reports prior to the scheduled submission of requested information. Implementation Date September 2024

GSA_MIGRATION

GSA_MIGRATION