SAN BERNARDINO COMMUNITY COLLEGE DISTRICTHigher Education

Criteria OMB Compliance Supplement, 34 CFR section 668.22(e)(f): The amount of Title IV assistance earned by the student is calculated by dividing the number of days completed by the student within the period of enrollment by the total number of days in the enrollment period. The enrollment period 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 the period of enrollment and the number of calendar days completed in that period. Condition Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance – For five of the sixty students tested, the District inaccurately calculated the amount of Title IV aid earned by students who withdrew from enrollment. Questioned Costs There are no questioned costs associated with the noncompliance. Context A non-statistical sample of 60 students out of 743 students, which had Return to Title IV calculations performed during the 2025 aid year. Effect The District is not in compliance with the federal R2T4 requirements described in the OMB compliance supplement. Cause The District’s internal controls over Return to Title IV calculations were not sufficient to ensure compliance with relevant requirements. Repeat Finding (Yes or No) No. Recommendation The District should review policies and procedures over the Return to Title IV calculations to ensure that the procedures are in line with the compliance requirements of the program. The District should strengthen internal controls over the review of the Return to Title IV calculations to ensure that the data utilized in preparing the calculation is accurate and that required funds are returned in a timely manner.

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 Federal Family Education Loan programs to 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, 21 of 60 students tested were not reported as having a change in enrollment status and/or withdrawal date to NSLDS (dates of change did not agree to NSLDS). In addition, 2 of those 21 students’ program of students were not reflected in NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context A non-statistical sample of 60 students out of 414 students, which had Return to Title IV calculations performed during the 2024 aid year. 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 to NSLDS timely or accurately. 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.

2021-001 Special Tests and Provisions Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, and 84.063 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirements OMB Compliance Supplement, 34 CFR section 668.173(b): Timing of Return of Title IV Funds Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initialed to ED or the appropriate FFEL lender 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 or the date on the canceled check shows the check was endorsed more than 60 days after the date of institution determined that the student withdrew. Condition Material Weakness ? At San Bernardino Valley College, the District?s portion of the Return to Title IV funds was not returned within the 45-day requirement for 4 out of the 15 students tested. In addition, both San Bernardino Valley College and Crafton Hills College utilized an incorrect academic calendar for use in their Return to Title IV calculations. Questioned Costs The utilization of an incorrect calendar within the District?s Colleague system resulted in underpayments to students of $1,332 for post withdrawal disbursements and an underpayment of the institutional portion of the amount to return of $11 at San Bernardino Valley College. The utilization of an incorrect calendar within the District?s Colleague system resulted in underpayments to students of $27 for post withdrawal disbursements. No questioned costs are associated with the untimely return of Return to Title IV funds. Context There were 715 Return to Title IV calculations completed for San Bernardino Valley College and 54 were completed for Crafton Hills College. Effect Without proper monitoring of student withdrawals, the District is at risk of noncompliance with the above referenced criteria. Use of an incorrect academic calendar can result in inaccurate percentage of term completed when processing Return to Title IV calculations. Cause The District?s policies and procedures were not properly adhered to. Repeat Finding Yes. See Finding 2020-002. Recommendation It is recommended that District should establish effective controls to ensure that Return to Title IV funds occurs within 45 days from the date the institution determines that student withdrew from all classes. The District should also establish controls to ensure that the input of the academic calendar into the Colleague systems is accurate.

2021-002 Special Tests and Provisions Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, and 84.063 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: Enrollment Effective Date ? The date that the current enrollment status reported for a student was first effective. ? OPEID Number ? This is the OPEID for the location that the student is actually attending. ? Enrollment Effective Date ? The date that the current enrollment status reported for a student was first effective. ? Enrollment Status ? The student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (Certification Date ? The Date enrollment certified by school. At a minimum, schools are required to certify enrollment every 60 days. ? G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: ? OPEID ? This is the OPEID for the location that the student is actually attending. ? CIP Code ? The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED?s National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. ? CIP Year ? Year for the corresponding CIP code. ? Credential Level ? Indicates the level of a credential the student will receive for the program the student is attending, for example undergraduate certificate, associate degree, or bachelor?s degree. ? Published Program Length Measurement ? The institution identifies whether the Published Program Length is in days, weeks, or years. ? Published Program Length ? Published Program Length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a). ? Program Begin Date ? The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. ? Program Enrollment Status ? The student?s enrollment status as of the reporting date; fulltime (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). ? Program Enrollment Effective Date ? The date that the enrollment status as of the reporting date reported for the program was first effective. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition Material Weakness ? During our review of the program reporting requirements, it was observed that the published program lengths that were being reported to NSLDS was inaccurate for 58 of the 60 students tested. The District reported the length of the program based on each individual student?s enrollment status at the time of reporting. This caused the published program lengths in some instances as being in excess of 7 years. This condition was noted at both San Bernardino Valley College and Crafton Hills College. For San Bernardino Valley College, this was observed in 41 out of the 43 students tested. For Crafton Hills College, this was observed in 17 out of the 17 students tested. Questioned Costs There are no questioned costs associated to the noncompliance. Context The District processed and disbursed Title IV Pell awards totaling $16,763,892 during the fiscal year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement Cause The District did not properly report the published program length for students under the Pell grant program via NSLDS. The administration of the Title IV programs depends heavily on the accuracy of enrollment and program information reported by institutions Repeat Finding No. Recommendation The District should implement a process to review, update, and verify program length information that appears on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

2021-003 Reporting Program Name: COVID-19 ? Higher Education emergency Relief Funds ? Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirements Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act requires that institutions that received a HEERF Section(a)(1) award to publicly post certain information on their website. Specific to the Student Aid Portion of this award, the following information is required, but not limited to, to be published and updated no later than 10 days after the end of each calendar quarter: ? The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter). ? The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act.[1] ? The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition Material Weakness ? During our testing over quarterly reporting for the Student Aid Portion for San Bernardino Valley College, we noted that two of the quarterly reports tested were missing several required reporting elements; support for some elements did not agree to reported amounts and were not uploaded onto the College?s website within the required 10 days from the end of each calendar quarter. During our testing over quarterly reporting for the Student Aid Portion for Crafton Hills College, we noted that two of the quarterly reports tested were missing several required reporting elements; support for some elements did not agree to reported amounts and were not uploaded onto the College?s website within the required 10 days from the end of each calendar quarter. We also noted that Crafton Hills College was unable to provide support that agreed to the amounts on their annual report submission. Questioned Costs There are no questioned costs associated to the noncompliance. Context Each College was required to complete and post on their website four quarterly reports and one annual report during the 2020-2021 year. Effect The required HEERF reporting elements for the Student Aid Portion award were not met. Cause The District did not have processes and procedures in place to monitor compliance with the reporting requirements described in Section 18004(a)(1). Repeat Finding No. Recommendation The District should ensure that reporting requirements and deadlines are clearly communicated to all staff, and procedures are in place to ensure that these requirements and deadlines are met. The District should also ensure that all documentation to support amounts being reported on the District/College websites are maintained in accordance with document retention guidelines.

2020-002 Special Tests and Provisions Program Name: Student Financial Assistance Cluster CFDA Number: 84.007,84.033, 84.063 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirement OMB Compliance Supplement, 34 CFR section 668.173(b): Timing of Return of Title IV Funds Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initialed to ED or the appropriate FFEL lender 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 or the date on the canceled check shows the check was endorsed more than 60 days after the date of institution determined that the student withdrew. Condition Significant Deficiency ? At San Bernardino Valley College, the District?s portion of the Return to Title IV funds was not returned within the 45 day requirement for 13 out of the 20 students tested. Questioned Costs No questioned costs as the funds were all returned to the Department of Education. Context There were 541 Return to Title IV calculations completed for Valley College and 30 were completed for Crafton Hills College. Effect Without proper monitoring of student withdrawals, the District is at risk of noncompliance with the above referenced criteria. Cause The District?s policies and procedures were not properly adhered to. Repeat Finding: Yes. See Finding 2019-002. Recommendation It is recommended the institution should establish effective controls to ensure the Return to Title IV funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

2020-003 Special Tests and Provisions Program Name: Student Financial Assistance Cluster CFDA Number: 84.007, 84.033, and 84.063. Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirement 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. Institutions are responsible for accurately reporting the following significant data elements under the Campus-Level Record that ED considers high risk: Enrollment Effective Date ? The date that the current enrollment status reported for a student was first effective. ? OPEID Number ? This is the OPEID for the location that the student is actually attending. ? Enrollment Effective Date ? The date that the current enrollment status reported for a student was first effective. ? Enrollment Status ? The student?s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (Certification Date ? The Date enrollment certified by school. At a minimum, schools are required to certify enrollment every 60 days. ? G), withdrawn (W), deceased (D), never attended (X) and record not found (Z) Institutions are responsible for accurately reporting the following significant data elements under the Program-Level Record that ED considers high risk: ? OPEID ? This is the OPEID for the location that the student is actually attending. ? CIP Code - The Classification of Instructional Programs (CIP) is a set of codes that define fields of study. CIP Codes are maintained by ED?s National Center for Education Statistics (NCES). They were most recently updated in 2020 and are usually updated every ten years. ? CIP Year ? Year for the corresponding CIP code. ? Credential Level ? Indicates the level of a credential the student will receive for the program the student is attending, for example undergraduate certificate, associate degree, or bachelor?s degree. ? Published Program Length Measurement ? The institution identifies whether the Published Program Length is in days, weeks, or years. ? Published Program Length - Published Program Length should be reported based on the definition of ?normal time? to completion in the regulations at 34 CFR 668.41(a). ? Program Begin Date ? The Program Begin Date is the date the student first began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program, unless the student enrolled in the program on an earlier date. ? Program Enrollment Status ? The student?s enrollment status as of the reporting date; fulltime (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). ? Program Enrollment Effective Date ? The date that the enrollment status as of the reporting date reported for the program was first effective. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition Significant Deficiency ? During our review of the enrollment reporting requirements it was observed that the enrollment effective date and the enrollment status was not accurately reported to NSLDS. The enrollment data for 1 student out of 40 tested for San Bernardino Valley College was not reported to NSLDS. Questioned Costs There were no questioned costs associated to the noncompliance. Context San Bernardino Valley College processed and reported Title IV awards for approximately 5,231 students during the fiscal year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students under the Pell grant and Direct and FFEL loan programs via NSLDS. The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Repeat Finding: 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.

Program Name: Student Financial Assistance Cluster CFDA Number: 84.007,84.003, 84.063 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirement OMB Compliance Supplement, 34 CFR section 668.173(b): Timing of Return of Title IV Funds Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initialed to ED or the appropriate FFEL lender 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 or the date on the canceled check shows the check was endorsed more than 60 days after the date of institution determined that the student withdrew. Condition Significant Deficiency ? At San Bernardino Valley College, the District's portion of the Return to Title IV funds was not returned within the 45 day requirement for 10 out of the 37 students tested. Questioned Costs No questioned costs as the funds were all returned to the Department of Education. Context There were 410 Return to Title IV calculations done for Valley College and 33 done for Crafton Hills College. Effect Without proper monitoring of student withdrawals, the District is at risk of noncompliance with the above referenced criteria. Cause The District's policies and procedures were not properly adhered to. Repeat Finding: No Recommendation It is recommended the institution should establish effective controls to ensure the Return to Title IV funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

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