Compton Community College DistrictHigher Education

Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.033, 84.007, 84.063, and 84.268 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 Federal family Education Loan (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 institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following instance was noted: 1. The student enrollment history per the college?s Banner system did not match the enrollment status reported to NSLDS for 1 of 60 students tested. Questioned Costs There are no questioned costs associated with this finding. Context The District disbursed approximately $4,908,526 in federal financial aid to students in the 2021-2022 fiscal year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District does not appear to have controls in place to ensure withdrawal dates are being properly reported to NSLDS. Repeat Finding (Yes or No) Yes. See prior year finding 2021-007 in the summary schedule of prior year audit findings. Recommendation The District should strengthen internal controls to ensure that withdrawal dates are being properly reported to NSLDS.

Program Name: COVID-19: Higher Education Emergency Relief Funds (HEERF), Student Aid Portion; COVID-19: Higher Education Emergency Relief Funds (HEERF), Institutional Portion Federal Assistance Listing Number: 84.425E, 84.425F 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 required that institutions that received the HEERF 18004(a)(1) Institutional and Student Aid Portions award to publicly post certain information on their website no later than 10 days after each calendar quarter, or as directed by the U.S. Department of Education. Condition Significant Deficiency in Internal Control over Compliance - During our testing over reporting for the Student Aid Portion, we noted that the report required to be publicly each quarter did not contain all the required elements. The estimated number of students 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, was not disclosed and updated for each reporting quarter. In addition, we noted that the quarterly reports for the Institutional and Student Aid portions were not made available on the District?s website within 10 days from the end of the quarter. Reports for the quarters ending September 30, 2020 and December 31, 2020 were posted on January 13, 2021. Questioned Costs There are no questioned costs associated with this finding. Context The District is required to report student and institutional grant metrics and other data within 10 days of the end of each calendar quarter, or as directed by the U.S. Department of Education. A sample of two reports from each program was reviewed for compliance, four in total, with all reports not submitted in a timely manner. Effect The College?s quarterly report was not uploaded to their website within the required timeframe. Cause The District does have a procedure in place; however, the reports were not filed in a timely manner. Repeat Finding (Yes or No) No. Recommendation The District should ensure that reporting requirements and deadlines are adhered to by all staff. The District should also ensure all documentation to support amounts reported is maintained in accordance with document retention guidelines.

Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirements According to 34 CFR 685.300(b)(5), the school must promise to comply with applicable regulations and must agree to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary, on a monthly basis as required by 34 CFR 685.300 (b)(5). Condition Material Weakness in Internal Control over Compliance ? During our review of the Direct Loans, it was noted that the District was unable to provide documentation to show that they were reconciling the institutional Direct Loan records with the School Account Statement (SAS) data file received by Common Origination and Disbursement (COD) on a monthly basis. Questioned Costs There are no questioned costs associated with this finding. Context The District disbursed approximately $334,287 in Direct Loan funds during the 2020-2021 fiscal year. Effect The District is out of compliance with 34 CFR 685.300(b)(5). Cause The District has not implemented policies and procedures to verify that the institutional Direct Loan records are being reconciled to the SAS data files on a monthly basis. Repeat Finding (Yes or No) Yes. See prior year finding 2020-005 in the summary schedule of prior audit findings. Recommendation It is recommended that the District develop and implement policies and procedures to ensure that the institutional Direct Loan records are being reconciled with the School Account Statement (SAS) data file received by Common Origination and Disbursement (COD) on a monthly basis.

Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirements Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency in Internal Control over Compliance ? The process dates reported in the COD files were more than 15 calendar days after the disbursement dates reported in the COD files in the District's financial records for the Fall and Spring semesters. Three students of the 40 students tested had transactions processed in excess of 15 days. Reporting days ranged from 24 to 73 days after disbursement for those students.Questioned Costs There are no questioned costs associated with this finding. Context The District processed and reported approximately $5,345,639 in Pell grants during the year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District does not have a process in place to ensure timely reporting to COD. Repeat Finding (Yes or No) Yes. See prior year finding 2020-006 in the summary schedule of prior audit findings. Recommendation It is recommended the District should establish effective controls and processes to ensure that reporting of student disbursement records is timely.

Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Pass-Through Entity: Direct Funded Criteria or Specific Requirements 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 (34 CFR 668.173(b)).Condition Significant Deficiency in Internal Control over Compliance ? During our testing over return of Title IV funds, we noted that in 4 instances out of the 18 calculations tested, the funds were not returned within 45 days after the District determined that the student withdrew. Questioned Costs There are no questioned costs associated with this finding. Context The District performed 89 Return to Title IV calculations during the 2020-2021 fiscal year. Effect Without proper monitoring of Title IV returns, the District is at risk of noncompliance with the above referenced criteria. Cause The District does not have a process in place to ensure that funds are returned in a timely manner. Repeat Finding (Yes or No) No. Recommendation The District should have a process in place to ensure that funds are returned no later than 45 days after the District has determined that a student has withdrawn.

Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.033, 84.007, 84.063, and 84.268 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 Federal family Education Loan (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 institution?s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information; ?Campus Level? and ?Program Level,? both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance ? During testing over the NSLDS reporting requirements, the following instances were noted: ? Student withdrawal effective dates per the college?s Banner system does not match the withdrawal date reported to NSLDS for 6 of 60 students tested. ? Student Certification Dates exceeded 60 days of the of the Effective Date of the status reported to NSLDS for 21 of 60 students tested. Questioned Costs There are no questioned costs associated with this finding. Context The District disbursed approximately $6,174,596 in federal financial aid to students in the 2020-2021 fiscal year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District does not appear to have controls in place to ensure that enrollment status changes are certified within the 60-day requirement and that withdrawal dates are being properly reported to NSLDS. Repeat Finding (Yes or No) Yes. See prior year finding 2020-004 in the summary schedule of prior audit findings. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

2020-002 Cash Management Program Name: COVID-19: CARES Act Higher Education Emergency Relief Funds, Student Aid Portion; Student Financial Assistance Cluster CFDA Number: 84.425E; 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Uniform Guidance, 2 CFR 200.305: Federal Payment (b) For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. See also ?200.302(b)(6). Except as noted elsewhere in this part, Federal agencies must require recipients to use only OMB-approved, governmentwide information collection requests to request payment. (1) Advance payments to a non-Federal entity must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the non- Federal entity in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the non-Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. The non-Federal entity must make timely payment to contractors in accordance with the contract provisions. Condition Significant Deficiency and Noncompliance ? The District drew down the entire allocation of $1,269,203 in funds available for the Higher Education Emergency Relief Funds - Student Aid Portion program on May 26, 2020. However, at June 30, 2020, the District had only spent $643,252 of these federal funds. The District did not minimize the time between receipt and disbursement of these funds requested, and as a result, held excess cash of $625,951 at June 30, 2020. For Federal Work Study and FSEOG programs of the Student Financial Assistance Cluster, the District drew down their entire award allocation for the 2019-2020 year on September 19, 2019. Neither program disbursed the amount drawn down or returned the funds within the required three days. Questioned Costs The questioned costs has not been identified at this time, however, the District needs to determine the interest earned on the excess cash and return those funds to the U.S. Department of Education. Context The District expended $643,252 and $10,511,220 for HEERF and Student Financial Aid Cluster, respectively. Effect The District is not in compliance with federal cash management requirements. Cause The District did not minimize the time between receipt and disbursement of the funds requested, and as a result, held excess cash at June 30, 2020. Repeat Finding: No Recommendation It is recommended that the District implement review process for all cash draw downs to ensure only funds needed for immediate disbursement are requested.

2020-003 Special Tests and Provisions ? Return to Title IV Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement The institution must return the lesser of (1) the total amount of unearned Title IV assistance to be returned or (2) an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student. If, for a non-term program an institution chooses to calculate the treatment of Title IV assistance on a payment period basis, but the institution charges for a period that is longer than the payment period, ?total institutional charges incurred by the student for the payment period? is the greater of (1) the prorated amount of institutional charges for the longer period, or (2) the amount of Title IV assistance retained for institutional charges as of the student?s withdrawal date (34 CFR 668.22(g)). Condition Significant Deficiency and Noncompliance ? There was no evidence that the District?s portion of the Return to Title IV was returned. Questioned Costs Questioned costs are funds not returned to the Department of Education of $155. Context The District performed 220 Return to Title IV calculations during the 2019-2020 fiscal year. There was one instance out of the 40 tested where the District was unable to provide evidence that Title IV funds were returned to the Department of Education. Effect Without proper monitoring of Title IV returns, the District is at risk of noncompliance with the above referenced criteria. Cause The District internal controls did not operate effectively to ensure the college submitted all required return of Title IV funds. Repeat Finding: No Recommendation It is recommended the District should establish effective controls to ensure the return of Title IV funds are properly calculated and returned.

2020-004 Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education 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 Federal family Education Loan (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 institution?s 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 Material Weakness and Noncompliance ? During testing over the NSLDS reporting requirements, it was noted that the college did not report any student information to NSLDS in the 2019-2020 fiscal year. The SCHER1 Report indicated that there were no submissions in the 2019-2020 fiscal year. The first submission appears to be on July 6, 2020. After further testing of specific students, the following were noted: ? Student withdrawal effective dates per the college?s system does not match the withdrawal date reported to NSLDS for 48 of 60 students tested. ? The student?s enrollment status per the college?s system does not match the status reported to NSLDS for 19 of 60 students tested. ? Since the first reporting date was not until July, 6, 2020, the timeliness of reporting enrollment status was outside of the required 60 days on all 60 students tested. ? The students? program in the college?s system does not match the students? program reported to NSLDS for three of 60 students tested. For two of these students, no enrollment records were reported to NSLDS. ? The students? program enrollment effective date in the college?s system does not match the students? program enrollment effective date reported to NSLDS for six of 60 students tested. ? one of 60 students tested was noted to have an undeclared major, but received Title IV funds in the 2019-2020 fiscal year. Questioned Costs There were $840 in questioned costs for aid disbursements associated with the undeclared major student identified in the condition. Context The District disbursed financial aid to approximately 3,765 students in the 2019-2020 fiscal year that required student enrollment and program enrollment reporting to NSLDS. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District appeared to have been unaware of requirement to update the Enrollment Reporting Rosters provided by NSLDS on a monthly basis. 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.

2020-005 Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan) Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement According to 34 CFR 685.300(b)(5), the school must promise to comply with applicable regulations and must agree to reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary, on a monthly basis as required by 34 CFR 685.300 (b)(5). Condition Material Weakness and Noncompliance ? During our review of the Direct Loans, it was noted that the District was unable to provide documentation to show that they were reconciling the institutional Direct Loan records with the School Account Statement (SAS) data file received by Common Origination and Disbursement (COD) on a monthly basis. Questioned Costs There are no questioned costs associated with this finding. Context The District disbursed approximately $493,559 in Direct Loan funds during the 2019-2020 fiscal year. Effect The District is out of compliance with 34 CFR 685.300(b(5. Cause The District has not implemented policies and procedures to verify that the institutional Direct Loan records are being reconciled to the SAS data files on a monthly basis. Repeat Finding: No Recommendation It is recommended that the District develop and implement policies and procedures to ensure that the institutional Direct Loan records are being reconciled with the School Account Statement (SAS data file received by Common Origination and Disbursement (COD on a monthly basis.

2020-006 Reporting Program Name: Student Financial Assistance Cluster CFDA Number: 84.033, 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Pass-Through Entity: Direct Funded Criteria or Specific Requirement Common Origination and Disbursement (COD) System (OMB No. 1845-0039) ? All schools receiving Pell grants submit Pell payment data to the Department of Education through the COD System. Institutions submit Pell origination records and disbursement records to the COD. Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Condition Significant Deficiency and Noncompliance ? The process dates reported in the COD files were more than 15 calendar days after the disbursement dates reported in the COD files in the District's financial records for the Fall and Spring semesters. Four students of the 40 students tested had transactions processed in excess of 15 days. Reporting days ranged from 29 to 197 days after disbursement. Questioned Costs There are no questioned costs associated with this finding. Context The District processed and reported approximately $9,593,110 in Pell grants during the year. Effect The District is not in compliance with the Federal requirements described in the OMB Compliance Supplement. Cause The District does not have a process in place to ensure timely reporting to COD. Repeat Finding: No Recommendation It is recommended the District should establish effective controls and processes to ensure that reporting of student disbursement records is timely.