Barstow Community College DistrictHigher Education

2022-001 Special Tests and Provisions ? Return to Title IV Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.063, 84.033, 84.007, 84.268 Federal Agency: U.S. Department of Education (ED) Directed funded by the U.S. Department of Education (ED) Criteria or Specific Requirement 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer 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 cancelled 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 - The District's portion of the Return to Title IV funds were not returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with this finding. Context The District performed approximately 20 Return to Title IV calculations related to direct loans during the 2021-2022 year. There was one instance out of thirty tested where the District's portion of the Return to Title IV funds were not returned within the 45-day requirement. Effect Without proper monitoring of Title IV returns, the District is at risk of noncompliance with the above referenced criteria. Cause The District's internal controls associated with the Return to Title IV procedures failed to ensure that all required funds were returned in a timely manner. Repeat Finding (Yes or No) No. Recommendation The District should strengthen procedures to ensure that the Return to Title IV funds are returned within 45 days from the date the District determines the student withdrew from all classes.

2022-002 Special Tests and Provisions ? Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.063, 84.033, 84.007, 84.268 Federal Agency: U.S. Department of Education (ED) Directed funded by the U.S. Department of Education (ED) 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. 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. Graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z). Institutions are responsible for timely reporting, whether they report directly or via a thirdparty servicer. Condition Significant Deficiency in Internal Control over Compliance - we noted the following noncompliance: 1. Student withdrawal effective dates per the college?s system does not match the withdrawal date reported to NSLDS for six out of sixty students tested. 2. Enrollment status was not reported to NSLDS for one out of sixty students tested. 3. Student enrollment status per the college?s system does not match the enrollment status reported to NSLDS for three out of sixty students tested. Questioned Costs There are no questioned costs associated with this finding. Context The District processed and disbursed Pell awards of $6,232,257 during the year ending June 30, 2022. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District?s policies and procedures were not properly adhered to. Repeat Finding (Yes or No) No Recommendation The District should strengthen internal controls to review, update, and verify enrollment information that appears on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

2021-003 Special Tests and Provisions ? Return to Title IV Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing Numbers: 84.063, 84.033, 84.007, 84.268 Federal Agency: U.S. Department of Education (ED) Directed funded by the U.S. Department of Education (ED) Criteria or Specific Requirement 34 CFR 668.22(j)(2): An institution must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. Condition Significant Deficiency in Internal Control over Compliance- The District did not calculate the withdrawal date within 30 days of the end of the academic period. Questioned Costs There are no questioned costs associated with this finding. The District did calculate the withdrawal date and perform the return to Title IV calculation; however, they did not calculate the withdrawal date within the 30-day requirement. Context There was 1 instance out of 36 tested where the District did not calculate the withdrawal date for the student within the 30-day requirement. Effect Without proper monitoring of accuracy and student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV calculations were performed in a timely manner. Repeat Finding (Yes or No) No Recommendation The District should implement procedures to ensure that the student withdrawal calculations are performed accurately and occur within 30 days from the end of the academic period.

2021-004 Reporting Program Name: COVID-19: Higher Education Emergency Relief Funds, Institutional Portion and COVID-19: Higher Education Relief Funds, Minority Serving Institutions (MSIs) Federal Financial Assistance Listing Numbers: 84.425F and 84.425L Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement Section 18004(a)(1) of The Coronavirus Aid, Relief, and Economic Security Act required that institutions that received the HEERF 18004(a)(1) Institutional Aid Portion and Minority Serving Institutions award to publicly post certain information on their website for each calendar quarter that can be reconciled with underlying documentation to ensure accuracy. Condition Significant Deficiency in Internal Control over Compliance - The quarters ended September 30, 2020 and December 31, 2020 quarterly public report and the annual report for Barstow College were tested. We noted that the federal funds reported on each report did not agree to the general ledger or other underlying documentation. Questioned Costs There are no questioned costs associated with this finding. Context The District has one college that was required to post forms covering the aggregate amounts spent for HEERF I quarterly and annually. Effect The documentation available for review was not adequate to support the compliance with the reporting requirements applicable to the program. Cause There was a lack of oversight in the quarterly and annual reporting requirements being reconciled with the underlying documentation. Repeat Finding (Yes or No) 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 underlying documentation supports amounts reported.

2020-003 Special Tests and Provisions ? Return to Title IV Program Name: Student Financial Assistance Cluster CFDA Number: 84.063, 84.033, 84.007 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement 34 CFR 668.173(b): Return of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic funds transfer 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 cancelled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency - The District's portion of the Return to Title IV funds were not returned within the 45 day requirement. Questioned Costs There are no questioned costs associated with this finding. The District did return the funds; however, they were not returned within the 45 day requirement. Context The District performed approximately 164 Return to Title IV calculations during the 2019-2020 year. There were fifteen instances out of twenty-five tested where the District's portion of the Return to Title IV funds were not returned within the 45 day requirement. Effect Without proper monitoring of Title IV returns, the District is at risk of noncompliance with the above referenced criteria. Cause The District's internal controls associated with the Return to Title IV procedures failed to ensure that all required funds were returned in a timely manner. Repeat Finding: No Recommendation The District should strengthen procedures to ensure that the Return to Title IV funds occurs within 45 days from the date the District determines the student withdrew from all classes.

2019-004 SPECIAL TESTS AND PROVISIONS - VERIFICATION Program Name: Student Financial Assistance Cluster CFDA Number: 84.063, 84.033, 84.007 Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirement 34 CFR section 668.53: (a) An institution must establish and use written policies and procedures for verifying an applicant's Free Application for Federal Student Aid (FAFSA) information in accordance with the provisions of this subpart. These policies and procedures must include?(1) The time period within which an applicant must provide any documentation requested by the institution in accordance with ?668.57;(2) The consequences of an applicant's failure to provide the requested documentation within the specified time period;(3) The method by which the institution notifies an applicant of the results of its verification if, as a result of verification, the applicant's Estimated Family Contribution (EFC) changes and results in a change in the amount of the applicant's assistance under the title IV, Higher Education Act (HEA) programs;(4) The procedures the institution will follow itself or the procedures the institution will require an applicant to follow to correct FAFSA information determined to be in error; and(5) The procedures for making referrals under ?668.16(g).(b) An institution's procedures must provide that it will furnish, in a timely manner, to each applicant whose FAFSA information is selected for verification a clear explanation of?(1) The documentation needed to satisfy the verification requirements; and(2) The applicant's responsibilities with respect to the verification of FAFSA information, including the deadlines for completing any actions required under this subpart and the consequences of failing to complete any required action.(c) An institution's procedures must provide that an applicant whose FAFSA information is selected for verification is required to complete verification before the institution exercises any authority under section 479A(a) of the HEA to make changes to the applicant's cost of attendance or to the values of the data items required to calculate the EFC. Condition Significant Deficiency ? The District's written policy does not have all of the requirements as listed in 34 CFR section 668.53. Questioned Costs There is no questioned costs associated with this finding. Context The District did not comply with the requirements noted in 34 CFR section 668.53. Effect The verification process supports eligibility determination; without proper written policies, the District is at risk of awarding ineligible students. Cause The District's written policy over verification has not been reviewed to ensure it complies with applicable Federal requirements. Repeat Finding: No Recommendation The District should review the existing verification policy and update it as necessary to ensure it complies with 34 CFR section 668.53.