MIRACOSTA COMMUNITY COLLEGE DISTRICTHigher Education

Special Tests and Provisions – Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007; 84.268; 84.033; 84.063 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (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 section 668.22(c): If an institution is not required to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the school, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the school of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, the following deficiencies were noted: - 26 of the 60 Return to Title IV calculations had a withdrawal determination date outside of the required timeframe. - 5 of the 60 Return to Title IV calculations were incorrectly calculated due to an error in the academic calendar loaded into the financial aid software. - 1 of the 60 Return to Title IV calculations were incorrectly calculated due to an error in the student’s academic status utilized in the calculation. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45-day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 431 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were calculated timely and accurately, and returned in a timely manner. Repeat Finding (Yes or No) No. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes and that the withdrawal determination is performed within the required timeframe. Additionally, the District should implement procedures to ensure that the academic calendar loaded in the financial aid software is accurate and based on the most up to date information. The District should also implement procedures to ensure that the correct student status is utilized in the calculation of Return to Title IV.

Program Name: COVID-19: Higher Education Emergency Relief Funds (HEERF), Student Aid Portion Federal Assistance Listing Number: 84.425E Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) 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) Student Aid Portion award to publicly post certain information on their website for each calendar quarter no later than ten days after the end of each calendar quarter. Condition Significant Deficiency in Internal Control over Compliance ?During our testing over reporting for the student aid portion at the District, we noted that the underlying supporting documentation for the following components did not agree to what was reported on the District?s quarterly report for the quarter ended March 31, 2021. Questioned Costs None noted. Context The District has one college that was required to report student grant metrics and other data on a quarterly basis on the District?s website. Although the report was submitted timely, we noted that the underlying supporting documentation for the required key line items did not agree to the District?s report. Out of the 4 required key line items, 3 of the items were misstated on the quarterly report. The total amount of Emergency Financial Aid Grants distributed to students under CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms was understated by $29,295. The total number of students who had received an Emergency Financial Aid grant was overstated by 31 students. In addition, the estimated total number of students at the institution who were eligible to receive an Emergency Financial Aid Grant was understated by 15,910. Effect The District did not comply with the federal reporting requirements. Cause The District did not have an adequate recordkeeping process in place. Repeat Finding (Yes or No) No. Recommendation It is recommended that the District instill adequate recordkeeping processes in addition to maintaining the support in accordance with documentation retention guidelines.

Program Name: Student Financial Assistance Cluster CFDA Numbers: 84.007,84.033, 84.063 and 84.268 Direct funded by the U.S. Department of Education (ED) Federal Agency: U.S. Department of Education (ED) Criteria or Specific Requirement Timing of Return of Title IV Funds ? 34 CFR section 668.173(b): Returns of Title IV funds are required to be deposited or transferred into the Student Financial Assistance (SFA) account or electronic fund transfers initialed to ED or the appropriate Federal Family Education Loan (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 ? The District?s portion of the Return to Title IV (R2T4) funds was not returned within the 45 day requirement for two students tested. Questioned Costs No questioned costs as the funds were all returned to the Department of Education. Context The District performed 377 R2T4 calculations during the 2019-2020 fiscal year. Of the 40 records tested, two instances were noted in which the District did not return the Title IV funds within the required 45-day timeframe. One student was returned in 62 days, while the other was returned in 66 days. Cause The District internal controls did not operate effectively to ensure the college submitted funds in a timely manner, within the 45 day requirement. Effect The District did not comply with federal requirements associated with the Return to Title IV process. Repeat Finding from Prior Year: No Recommendation It is recommended the District should establish effective controls to ensure the Return of Title IV funds occurs within 45 days from the date the District determines the student withdrew from all classes.

Program Name: COVID-19: CARES Act Higher Education Emergency Relief Funds (HEERF), Student Aid Portion CFDA Numbers: 84.425E Direct funded by the U.S. Department of Education (ED) Federal Agency: 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) Student Aid Portion award to publicly post certain information on their website no later than 30 days after their award allocation date, and update that information every 45 days thereafter. Condition Significant Deficiency ? During our testing over reporting for the student aid portion at the District, we noted that the report required to be publicly available 30 days following the award becoming available was late by 81 days and therefore, the District did not meet the timeliness requirement. Questioned Costs None reported. Context The District has one college that was required to report student grant metrics and other data within 30 days of their award allocation date. The report was reviewed for compliance, noting it was not submitted in a timely manner. Cause The District did not have an effective procedure in place to ensure the initial report was filed timely. Effect The District did not comply with the federal reporting requirements. Repeat Finding from Prior Year: No Recommendation It is recommended the District should establish a procedure to ensure timeliness of reporting requirements is met.