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Arizona · Local government · $50M-$250M in federal spending

Maricopa County Community College District

Tempe, AZ

The FY2025 single audit reports 1 finding: 1 significant deficiency. Audits on file for FY2023–FY2025: FY2023, FY2024, FY2025.

Score: 3 of 100 (FY2025 audit)

The sum of eight parts, each read from the audit. How the score works.

PartRulePointsMax
Material weaknesses8 points each024
Significant deficiencies3 points each39
Repeat findings5 points each015
Longest repeat chain2 years 3, 3 years 6, 4 years 9, 5+ years 12012
Modified major-program opinionsqualified 8 each; any adverse or disclaimer 15015
Questioned costsknown amount of $25,000 or more, by share and dollars015
Going concernauditor included a going-concern paragraph05
Prior-year latenessprior-year audit late or not filed, scored only with a finding05
Score3100

Federal funding, FY2025

$207,177,735 in federal awards spent, across 27 programs. Largest funding agencies:

AgencySpent
Department of Education$188,890,355
Department of the Treasury$11,099,184
Small Business Administration$3,019,080

FY2025 audit

FAC record
2025-06-GSAFAC-0000407889
Fiscal year end
June 30, 2025
Accepted by FAC
March 25, 2026
Federal spending
$207,177,735 · 27 programs
Major programs
5
Score
3 of 100

Finding 2025-101

significant deficiencyother matters

Program
STUDENT FINANCIAL ASSISTANCE (84.007, 84.033, 84.038 and 2 more)
Compliance requirement
Special tests and provisions
FAC record
FY2025 audit on fac.gov
Finding text from the filing

FEDERAL AWARD FINDING: 2025-101 The District did not timely return Title IV funds to the U.S. Department of Education, increasing the risk of reduced or terminated future awards Cluster name: Student Financial Assistance Cluster Assistance Listings number(s) and name(s): 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program—Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award number(s) and year(s): P063P241066 July 1, 2024 to June 30, 2025 P007A240115 July 1, 2024 to June 30, 2025 P033A240115 July 1, 2024 to June 30, 2025 P268K241066 July 1, 2024 to June 30, 2025 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions - return of Title IV funds Questioned costs: None Condition Contrary to federal regulation and the District’s policies and procedures, the District’s Student Financial Services Office (SF Office) did not initiate a return of Title IV funds to the U.S. Department of Education (ED) within the required 45 days of becoming aware that a student withdrew from the District. Specifically, for 3 of 25 students tested, the District did not initiate returns until between 71 and 83 days after becoming aware the students withdrew. Effect The District’s failure to timely return Title IV funding and the lack of monitoring over the SF Office’s compliance with federal regulation and District policies and procedures increases the risk that additional Title IV funds could be returned past the 45-day requirement and increases the risk that ED could reduce or terminate future awards of Title IV funds for noncompliance.

Cause The District did not monitor its SF Office’s adherence to District-wide policies and procedures to ensure compliance with Title IV program requirements. Specifically, although the District had communicated District-wide policies to the SF Office that is responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, the District did not have procedures in place to monitor and address employee turnover of personnel responsible for adherence to District-wide policies regarding timely return of Title IV funds. Criteria Federal regulation and District policies and procedures require the return of Title IV funds when a recipient of Title IV grant or loan assistance withdraws from the District during a payment period or period of enrollment in which the recipient began attendance. Specifically, the District must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistances earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs no later than 45 days after the date of the District’s determination that the student withdrew (34 Code of Federal Regulations [CFR] §668.22[a –j]). Further, federal guidelines require establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the District 1. Monitor its SF Office to ensure its compliance with District policies and procedures for the return of Title IV funds. 2. Design and document control procedures to monitor and address employee turnover of personnel responsible for performing procedures related to the return of Title IV funds. 3. Initiate returns of Title IV funds to ED no later than 45 days after the date of the District’s determination that the student withdrew. Views of responsible officials District management concurs with this finding. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials regarding these recommendations. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

FY2024 audit

FAC record
2024-06-GSAFAC-0000355817
Fiscal year end
June 30, 2024
Accepted by FAC
March 31, 2025
Federal spending
$171,561,595 · 34 programs
Major programs
5; qualified opinion on 2
Questioned costs
$73,165 known
Score
29 of 100

Finding 2024-101

significant deficiency

Program
CHILD CARE AND DEVELOPMENT BLOCK GRANT (93.575)
Compliance requirement
Reporting
FAC record
FY2024 audit on fac.gov
Finding text from the filing

Assistance Listings number and name: 93.575 Child Care and Development Block Grant Award numbers and years: DI22-002326, July 1, 2023 through June 30, 2024; P00003796, July 1, 2023 through June 30, 2024; P0001273602, July 1, 2023 through June 30, 2024 Federal agency: U.S. Department of Health and Human Services Pass-through grantor: Arizona Department of Economic Security Compliance requirements: Reporting Questioned costs: Not applicable

Condition—Contrary to federal regulation, the District’s Student Affairs Department (Department) did not develop, document, or implement internal control procedures to monitor compliance with the program’s reporting requirements. Specifically, for all 4 federal program reports we tested, the Department did not retain documentation that it had reviewed and approved reports prior to submitting them to the pass-through grantor to ensure the reported expenditures were accurate and agreed to the District’s records, and contained only allowable expenses. Despite lacking internal control procedures, we did not identify any inaccurate program information reported to the pass-through grantor.

Effect—Without effective internal control procedures in place, there is an increased risk that the Department may not prevent or detect and correct errors on reports it submits to the pass-through grantor, which relies on them to effectively monitor the program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program's success. Finally, the District is at risk that this finding applies to other federal programs it administers.

Cause—The Department’s management reported that it had performed independent reviews and approvals of the reports but did not maintain documentation because the District did not have a formal policy requiring a documented review and approval of its reports.

Criteria—Federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendation—The Department should develop, document, and implement policies and procedures, and train responsible employees, to monitor compliance with the program’s reporting requirements, including processes to perform and document an independent review and approval of all federal program reports before submitting them to the pass-through grantor to ensure reports are accurate, agree to District records, and contain only allowable expenditures.

The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

Finding 2024-102

material weaknessquestioned costsmodified opinion

Program
HIGHER EDUCATION_INSTITUTIONAL AID (84.031); U.S. Department of Education (84.002)
Compliance requirement
Activities allowed or unallowed; Allowable costs/cost principles
Questioned costs
$73,165 (known)
FAC record
FY2024 audit on fac.gov
Finding text from the filing

Assistance Listings number and name: 84.002 Adult Education—Basic Grants to States Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024; 24FIELCC-412421-01A, July 1, 2023 through June 30, 2024; 24FIETCO-412421-01A, July 1, 2023 through June 30, 2024; 24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024; 24FIECTC-412421-01A, July 1, 2023 through June 30, 2024 Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles Questioned costs: $52,754 Assistance Listings number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096, October 1, 2020 through September 30, 2025; P031S200281, October 1, 2020 through September 30, 2025; P031C210057, October 1, 2021 through September 30, 2026; P031C210077, October 1, 2021 through September 30, 2026; P031S220015, October 1, 2022 through September 30, 2027; P031S220179, October 1, 2022 through September 30, 2027; P031A230147, October 1, 2023 through September 30, 2028; P031S230158, October 1, 2023 through September 30, 2028 Compliance requirements: Activities allowed or unallowed Questioned costs: $20,411 Federal agency: U.S. Department of Education Total questioned costs: $73,165

Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information.

Table 1 Summary of the $73,165 of payroll costs the District did not properly support or approve Fiscal year 2024

84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs Total employees tested 35 19 54 Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8 Total unsupported payroll costs $52,366 $9,636 $62,002 Total employee time sheets lacking approval after the work was performed2 2 12 14 Total unapproved payroll costs $388 $10,775 $11,163 Total number of employees with unsupported or unapproved payroll costs 9 13 22 Total salaries not supported $52,754 $20,411 $73,165

Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers.

Table 2 Calculation of percent of payroll costs to total program expenditures Fiscal year 2024

84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total number of employees 279 214 Total payroll costs $3,613,133 $1,984,462 Total program costs $5,026,228 $6,696,263 % of payroll costs to total program costs 72% 30%

Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required.

Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendations—The District should:

1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions. 2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs. 3. Enforce and train employees on District written procedures and requirements to: a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor. b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated. 4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees.

The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

1 [the auditor]. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf 2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee. 3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual. 5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf 6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.

FY2023 audit

FAC record
2023-06-GSAFAC-0000027656
Fiscal year end
June 30, 2023
Accepted by FAC
March 29, 2024
Federal spending
$226,256,481 · 32 programs
Major programs
4; qualified opinion on 2
Questioned costs
$5,612 known
Score
74 of 100

Finding 2023-101

material weaknessrepeat findingquestioned costsmodified opinion

Program
STUDENT FINANCIAL ASSISTANCE (84.007, 84.033, 84.038 and 2 more)
Compliance requirement
Special tests and provisions
Repeat
Chain of at least 9 audit years; prior finding 2022-101
Questioned costs
amount not determinable
FAC record
FY2023 audit on fac.gov
Finding text from the filing

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program—Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2022 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirements: Special tests and provisions Questioned costs: Unknown

Condition—Contrary to federal regulations and District policies and procedures, the District’s Student Financial Assistance Offices (Offices) at 7 of its 10 colleges did not accurately and/or timely report enrollment status changes to the National Student Loan Data System (NSLDS) for 20 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the Offices did not report:

• Timely student enrollment status changes for 10 students, as the Offices reported the changes between 3 to 56 days later than the required 60 days. • Accurate student enrollment status changes for 15 students, as the Offices reported incorrect changes for these students, 5 of which were reported late, as described above.

Effect—The District’s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students’ enrollment status.

Cause—The District did not monitor its Student Financial Assistance Offices’ adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges’ adherence to them to ensure student data is reported accurately and timely. Thus, when the SFA offices at 7 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District’s student information system before submitting reports to NSLDS, the District did not identify the errors and did not report student enrollment status changes timely.

Criteria—Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students’ enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students’ change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] §§685.309[b][2] and 690.83[b][2]). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendations—The District should:

1. Require its Student Financial Assistance Offices to follow District-wide policies and procedures to: a. Report accurate student enrollment statuses and changes to the NSLDS within 60 days of the students’ change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. Monitor its Student Financial Assistance Offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs.

The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2015.

Finding 2023-102

material weaknessrepeat findingquestioned costsother matters

Program
TRIO CLUSTER (84.042, 84.047)
Compliance requirement
Eligibility
Repeat
Chain of 2 audit years; prior finding 2022-105
Questioned costs
$5,612 (known)
FAC record
FY2023 audit on fac.gov
Finding text from the filing

Cluster name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO—Student Support Services 84.047 TRIO—Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022; P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025; P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $5,612

Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:

• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures. • For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.

Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:

• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.

Effect—Without performing independent reviews and approvals of eligibility determinations that the colleges’ policies and procedures require, GateWay and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2

Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.

Criteria—GateWay Community College’s written policies and procedures require employees to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College—TRIO Upward Bound Eligibility Determination and Intake Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendations—The District should:

1. Require all the District colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants. 2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures. 3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.

The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

This finding is similar to prior-year finding 2022-105 and was initially reported in fiscal year 2022.

1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)

Finding 2023-103

material weaknessrepeat findingquestioned costsmodified opinion

Program
HIGHER EDUCATION_INSTITUTIONAL AID (84.031)
Compliance requirement
Reporting; Special tests and provisions
Repeat
Chain of 3 audit years; prior finding 2022-104
Questioned costs
no amount stated
FAC record
FY2023 audit on fac.gov
Finding text from the filing

Assistance Listing number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096 and P031S200281, October 1, 2020 through September 30, 2025; P031C210057 and P031C210077, October 1, 2021 through September 30, 2026; P031S220015 and P031S220179, October 1, 2022 through September 30, 2027 Award year: July 1, 2022 through June 30, 2023 Federal agency: U.S. Department of Education Compliance requirement: Reporting and special tests and provisions Questioned costs: N/A

Condition—The District did not act in accordance with several federal regulations for its 10 endowments that 6 of the District’s 10 colleges established with Higher Education—Institutional Aid (HEIA) program monies that have been held by its Foundation since 2005. The District’s 10 endowments held with the Foundation ranged in value from $66,200 to $367,000 with a combined fiscal year-end balance of $1.7 million, including interest earned.1 Specifically, based on our review of the 10 required annual endowment reports, we found that the District and colleges did not:

• Submit 1 of the 10 required reports to the U.S. Department of Education to certify that endowment monies were spent in accordance with federal requirements. • Review and approve 2 of 2 reports tested prior to submitting them to the U.S. Department of Education, and we noted that these 2 reports did not agree to Foundation records.

In addition, we found that the District and colleges were not aware of and did not evaluate each endowment’s investment performance with the Foundation and did not ensure that the Foundation’s investment policies met federal requirements.

Effect—The District’s failure to submit accurate endowment reports and the lack of monitoring over the Foundation’s administration of its endowments increases the risk that the U.S. Department of Education could terminate the endowments and require the District to reimburse it for the original endowment balances, including interest earned, if the District spent more of the endowments’ income than allowed by federal regulations. We did not note any instances of the District spending more than allowed based on the 2 reports tested.

Cause—The District reported that all the endowment reports submitted to the U.S. Department of Education were prepared by the Foundation and submitted by the colleges. However, the District did not have policies and procedures requiring the colleges to review the reports for accuracy, before they were submitted to the U.S. Department of Education. In addition, the District’s colleges separately contracted with the Foundation to administer the endowments, which included investing the endowment balances and disbursing a portion of the interest earned for allowable program activities. However, the District did not ensure that the Foundation was aware of the program’s requirements or have a plan for ensuring compliance. Further, the District did not have written policies and procedures to monitor the Foundation’s contract and the District’s endowments held with the Foundation, and had not designated anyone to centrally monitor these endowments.

Criteria—Federal regulation permits the District to designate its Foundation to invest and raise monies for the program’s endowments; however, the District is ultimately responsible for ensuring its endowments are administered in accordance with all federal regulations (34 CFR §628.3). The District is required to monitor the Foundation’s compliance with all federal requirements, including those that specify the investment types and risks allowed; require the endowments’ corpuses remain unspent during the grant award period; ensure it spends no more than 50 percent of the endowments’ earnings in accordance with the endowments’ purpose; and verify that endowment income is properly calculated and invested in a savings account or low-risk securities (34 CFR §§628.43 through .46). Additionally, federal regulation and the District colleges’ federal program award terms require the District to submit annual reports for each of its endowments certifying that the endowments comply with federal regulations (34 CFR §628.47[f]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendations—The District should develop and implement written policies and procedures to:

1. Require the colleges to review reports for accuracy prior to certifying them and submitting them to the U.S. Department of Education. 2. Update its endowment contracts with the Foundation to include provisions that: a. Require the Foundation to provide information on each endowment to the District for inclusion in the annual reports. b. Specify the types of investments and investment risks allowed by federal regulations. c. Require the Foundation to provide periodic reporting to the District and applicable colleges about the endowments’ investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations. 3. Designate an employee to centrally monitor the endowments with the Foundation to ensure the endowments are properly accounted for, spent, and invested in accordance with federal regulations. 4. Ensure that the District’s required endowment annual reports are certified and submitted to the U.S. Department of Education by the District only after the reports have been reviewed and approved for accuracy and agreement to the Foundation’s records by the responsible District employee.

The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

This finding is similar to prior-year finding 2022-104 and was initially reported in fiscal year 2021.

1 The endowment grant award numbers and years are as follows: P031010003, October 1, 2001 through September 30, 2006; P031S080044, October 1 2007 through September 30, 2012; P031S080118, October 1, 2008 through September 30, 2014; P031S090050, October 1, 2009 through September 30, 2014; P031A110194, October 1, 2011 through September 30, 2016 (2 endowments); P031A110200, October 1, 2011 through September 30, 2017; P031S150085, October 1, 2015 through September 30, 2020; P031S150098, October 1, 2015 through September 30, 2021; and P031S160090, October 1, 2016 through September 30, 2023.