Victor Valley Community College DistrictHigher Education

Criteria or Specific Requirement: In accordance with 34 CFR 668.22(j), An institution that is not required to take attendance 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 / Context: During our audit procedures, we noted that 20 out of 25 selections had forms that were completed after the end of the fall term, outside of the 30-day limit. Additionally, all forms appeared to have used the same drop date, regardless of the student’s actual drop date determination. Questioned Costs: None. Cause: Inadequate controls over the R2T4 process, resulting from turnover in the financial aid office. Effect: A lack of internal controls can result in noncompliance with provisions of the various programs within the Student Financial Assistance Cluster. Repeat Finding: No. Recommendation: We recommend the Colleges reinforce their review processes related to student drops and review all activity level controls to ensure compliance with the various requirements of the Student Financial Assistance Cluster. Additionally, when there is turnover, there should be adequate training within the department to ensure that another member of the team is available to meet the applicable compliance requirements.

2021-001 Special Tests and Provisions ? Disbursements to or on Behalf of Students Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR 668.165(a): (1) Before an institution disburses title IV, Higher Education Act (HEA) program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from Parent Loan for Undergraduate Students (PLUS) loans. (2) Except in the case of a post-withdrawal disbursement made in accordance with ? 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or Teacher Education Assistance for College and Higher Education (TEACH) Grant program funds, the institution must notify the student or parent of - (i) The anticipated date and amount of the disbursement; (ii) The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary of the Department of Education; and (ii) The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. (3) The institution must provide the notice described in paragraph (a)(2) of this section in writing (i) No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at the institution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section. 34 CFR 685.300(b)(9): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to provide for the implementation of a quality assurance system, as established by the Secretary of the Department of Education and developed in consultation with the school, to ensure that the school is complying with program requirements and meeting program objectives. Condition Significant Deficiency ? The District provided notice of the disbursement of Direct Loan funds earlier than 30 days before crediting a student?s account. In addition, the District did not have a Direct Loan quality assurance system documented. Questioned Costs There were no questioned costs associated with this finding. Context The District disbursed $61,612 in Direct Loan program funds during the 2020-2021 year. Effect Without a documented Direct Loan quality assurance system and proper monitoring, the District is not in compliance with the above references criteria. Cause The District?s controls associated with the Direct Loan program failed to ensure that proper procedures were followed and documented over the disbursements to and on behalf of students. Repeat Finding (Yes or No) No Recommendation The District should develop, document, and implement procedures over the Direct Loan program to ensure that program compliance requirements are adhered to and written notifications are obtained within the appropriate timeframe.

2021-002 Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan) Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR 685.300(b)(5): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to, on a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary of the Department of Education and Direct Loan disbursement records submitted to and accepted by the Secretary of the Department of Education. Condition Significant Deficiency ? The District did not perform monthly reconciliations between institutional records and School Account Statement (SAS) data files received by the Department of Education?s Common Origination and Disbursement (COD). Questioned Costs There were no questioned costs associated with this finding. Context The District disbursed $61,612 in Direct Loan program funds during the 2020-2021 year. Effect The District is out of compliance with 34 CFR 685.300(b)(5). Cause The District?s controls associated with the Direct Loan program failed to ensure that proper procedures were followed over the monthly reconciliation of institutional records and SAS data files received by COD. Repeat Finding (Yes or No) No Recommendation The District should develop and implement procedures over the Direct Loan program to ensure that program compliance requirements are adhered to and monthly reconciliations are being performed between institutional records and SAS data files received by COD.

2021-003 Reporting Program Names: COVID-19: Higher Education Emergency Relief Funds, Student Aid Portion; COVID-19: Higher Education Emergency Relief Funds, Institutional Portion Federal Assistance Listing Numbers: 84.425E, 84.425F 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 (CARES) Act required that institutions that received the HEERF 18004(a)(1) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award and update that information every 45 days thereafter. This was amended on August 31, 2020 to decrease the frequency of reporting from every 45 days thereafter to every calendar quarter. The reports must be updated no later than 10 days after the end of each calendar quarter. In addition, Section 18004(a)(1) of the CARES Act required that institutions that received the HEERF 18004(a)(1) Institutional Portion award to publicly post expenditure reports on a quarterly basis. Each report is separate for the calendar quarter and not cumulative. Condition Significant deficiency -The District?s student aid quarterly report did not contain all of the required reporting elements. The District?s institutional quarterly report did not accurately report the quarterly program expenditures. Cause The District did not publicly report the estimated total number of students at the institution that are eligible to receive emergency financial aid grants to students under the Student Aid Portion program. The District?s institutional quarterly report was not a separate report for the quarter ended in that cumulative expenditure amounts were reported for the Institutional Portion program. Effect The District is not in compliance with reporting requirements under Section 18004(a)(1) for the Student Aid and Institutional Portion programs. Questioned Costs There were no questioned costs associated with this finding. Context The District was required to report student grant metrics and other data no later than 10 days after each calendar quarter end. The report was reviewed for compliance noting it did not contain all of the required reporting elements. The District was required to report program expenditures for each calendar quarter for the Institutional Portion program. The report was reviewed for compliance noting the expenditures reported were reported cumulatively. Repeat Finding (Yes or No) Yes, see summary schedule of prior audit findings, finding 2020-001. Recommendation The District should ensure that reporting requirements 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.

2020-001 Reporting Direct Programs ? U.S. Department of Education CFDA# 84.425E COVID-19 - Higher Education Emergency Relief Funds ? Student Portion 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) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award and update that information every 45 days thereafter. Condition Significant Deficiency - During our testing over reporting for the student aid portion, we noted that the 30 day report did not contain all of the required reporting elements. Cause The District did not publicly report the amount of Emergency Aid Grant that a student would receive under the program. Effect The District?s 30 day report did not contain all of the required reporting elements. Questioned Costs None reported Context The District was required to report student grant metrics and other data no later than 30 days after their award allocation date. The report was reviewed for compliance noting it did not contain all of the required reporting elements. Repeat Finding from Prior Year No Recommendation The District should ensure that reporting requirements 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.

Program Name: Student Financial Assistance Cluster CFDA Number: 84.063 Federal Agency: U.S. Department of Education Criteria or Specific Requirement OMB Compliance Supplement, 34 CFR section 668.22(j): Timing of Return of Title IV Funds 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. The institution must also notify the recipient of Title IV loans returned (34 CFR 685.306(a)(2)). Condition Significant Deficiency - The institution did not determine the withdrawal dates for each of the students noted below in a timely manner. Questioned Costs No questioned costs. Context Out of the 25 calculations tested, the District had five untimely withdrawal determination dates. Effect Without proper monitoring of student withdrawals, the District risks noncompliance with the above referenced criteria. Cause The institution did not determine withdrawal dates for the students within 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. Repeat Finding: No Recommendation It is recommended the District should design and implement procedures that will allow for the timely identification of dropped students when performing the Return to Title IV calculation. Management's Response We concur.