Alamo Community College District

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: September 1, 2024 – August 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The U.S. Department of Education offers financial aid to students under two programs: 1. Pell Grant program which provides grants to eligible students enrolled in eligible undergraduate programs and certain post-baccalaureate teacher certificate programs and 2. FSEOG program which provides grants to eligible undergraduate students with priority given to Pell recipients who have the lowest expected family contributions. Condition: The Pell Grant Program has maximum and minimum Pell grant awards established by statute and should be awarded based on the student's needs. During our testing, we noted that one of the sixty students tested was over awarded Pell funds. Questioned Costs: $1,849 Context: A system defect impacted Pell Grant disbursements, prompting the District to disable standard attending hours functionality. Attending hours were then locked in February for the Spring term. Subsequent enrollment changes requiring manual Pell Grant adjustments were missed due to human oversight, resulting in an over award of $1,849. Cause: The District's internal control process was not able to detect the over awarding of the Pell amounts. Effect: One student was over awarded $1,849 Repeat Finding: No Recommendation: We recommend the District evaluate the student’s status each semester. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: September 1, 2024 – August 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b) and 34 CFR 682.610(c) states that because a student begins earning Title IV funds on the first day of attendance, even if the student withdraws before a school’s census date, the school must perform an R2T4 calculation using the number of days or the number of scheduled clock hours the student attended class. The school must include in the R2T4 calculation all forms of Title IV aid that were disbursed or that could have been disbursed, even if the student receives a full tuition refund. Condition: We noted that one of the sixty students tested was not calculated for an R2T4 in the current year when they should have been. Questioned Costs: $3,199 Context: The student withdrew from the District mobile app, bypassing required advisor approval. This prevented the R2T4 workflow from recognizing the withdrawal, and the R2T4 calculation was delayed until identified. Cause: The District did not evaluate the student for R2T4. Effect: One of the students were not calculated. Repeat Finding: No Recommendation: We recommend the District should implement a comprehensive review process for R2T4 calculations and financial aid withdrawal listings to ensure all student withdrawals are accurately identified and processed in a timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans

Federal Award Identification Number and Year: N/A

Award Period: September 1, 2022 to August 31, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters

Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi).

In addition, per Uniform Guidance 2 CFR 200.303, federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.

Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs.

Questioned Costs: None

Context: During our review of the GLBA reports for Alamo Community College District, we noted one of the eight required GLBA safeguards was missing from the written information security plan (District’s Enterprise Data Governance Standard), and there was no review of the plan.

Cause: The Enterprise Data Governance Standard did not include one of the required GLBA safeguards.

Effect: The District is not in full compliance with GLBA.

Repeat Finding: No

Recommendation: We recommend that the District review the updated GLBA requirements and ensure their Enterprise Data Governance Standard includes all required elements.

Views of Responsible Officials: There is no disagreement with the audit finding. The District has a plan to correct the finding.

Federal Agency: Department of Education Federal Program: Education Stabilization Fund Assistance Listing Number: 84.425E

Federal Award Identification Number and Year: N/A

Award Period: September 1, 2022 to August 31, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters

Criteria or Specific Requirement: In accordance with 2 CFR Section 200.407, institutions distributing HEERF funding are required to ensure that students meet the eligibility requirements of the program while following established policies and procedures.

In addition, per Uniform Guidance 2 CFR 200.303, entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements.

Condition: During our testing of student expenditures of HEERF funding, we identified certain internal control policies of the District were not followed.

Questioned Costs: None

Context: During our testing of the HEERF student expenditures, we identified certain instances where internal control policies of the District were not followed at Northwest Vista College.

Cause: The District in certain instances did not follow the internal control policies implemented around the awarding of HEERF student funds.

Effect: There were certain instances where HEERF funds were disbursed that did not follow the District’s internal control policies.

Repeat Finding: No

Recommendation: We recommend that the District review their internal processes and ensure all internal control policies are followed.

Views of Responsible Officials: There is no disagreement with the audit finding. The District has a plan to correct the finding.