COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI St. Louis, Missouri OMB CIRCULAR A-133 SINGLE AUDIT REPORT June 30, 2015 TABLE OF CONTENTS PAGE INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS.......................................................................... 1 INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE WITH REQUIREMENTS THAT COULD HAVE A DIRECT AND MATERIAL EFFECT ON EACH MAJOR FEDERAL PROGRAM AND ON INTERNAL CONTROL OVER COMPLIANCE AND ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS IN ACCORDANCE WITH OMB CIRCULAR A-133 ............................................................. 3 SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS .................................................... 6 NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS ............................... 10 SCHEDULE OF FINDINGS AND QUESTIONED COSTS....................................................... 12 SCHEDULE OF STATUS OF PRIOR FINDINGS.................................................................... 16 CliftonLarsonAllen LLP CLAconnect.com INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS Board of Trustees Community College District of St. Louis, St. Louis County, Missouri St. Louis, Missouri We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to the financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of the business-type activities and the remaining fund information of the Community College District of St. Louis, St. Louis County, Missouri (College) as of and for the year ended June 30, 2015, and the related notes to the financial statements, which collectively comprise the College’s basic financial statements, and have issued our report thereon dated January 28, 2016 Internal Control Over Financial Reporting In planning and performing our audit of the financial statements, we considered the College’s internal control over financial reporting (internal control) to determine the audit procedures that are appropriate in the circumstances for expressing an opinion on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the College’s internal control. Accordingly, we do not express an opinion on the effectiveness of the College’s internal control. Our consideration of internal control was for the limited purpose described in the preceding paragraph and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that were not identified. However, as described in the accompanying schedule of findings and questioned costs, we identified a certain deficiency in internal control that we consider to be a material weakness. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance. We consider the deficiency described in the accompanying schedule of findings and questioned costs as item 2015-001 to be a material weakness. An independent member of Nexia International 1 Board of Trustees Community College District of St. Louis, St. Louis County, Missouri Compliance and Other Matters As part of obtaining reasonable assurance about whether the College’s financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit and, accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. College’s Response to Findings The College’s response to the finding identified in our audit is described in the accompanying schedule of findings and questioned costs. The College’s response was not subjected to the auditing procedures applied in the audit of the financial statements and, accordingly, we express no opinion on it. Purpose of this Report The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the result of that testing, and not to provide an opinion on the effectiveness of the entity’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose. a CliftonLarsonAllen LLP Peoria, Illinois January 28, 2016 2 CliftonLarsonAllen LLP CLAconnect.com INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE WITH REQUIREMENTS THAT COULD HAVE A DIRECT AND MATERIAL EFFECT ON EACH MAJOR FEDERAL PROGRAM, ON INTERNAL CONTROL OVER COMPLIANCE AND THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS IN ACCORDANCE WITH OMB CIRCULAR A-133 Board of Trustees Community College District of St. Louis, St. Louis County, Missouri St. Louis, Missouri Report on Compliance for Each Major Federal Program We have audited the Community College District of St. Louis, St. Louis County, Missouri’s (College) compliance with the types of compliance requirements described in the OMB Circular A-133 Compliance Supplement that could have a direct and material effect on each of its major federal programs for the year ended June 30, 2015. The College’s major federal programs are identified in the summary of auditors’ results section of the accompanying schedule of findings and questioned costs. Management’s Responsibility Management is responsible for compliance with the requirements of laws, regulations, contracts, and grants applicable to its federal programs. Auditors’ Responsibility Our responsibility is to express an opinion on compliance for each of the College’s major federal programs based on our audit of the types of compliance requirements referred to above. We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America; the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States; and OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. Those standards and OMB Circular A-133 require that we plan and perform the audit to obtain reasonable assurance about whether noncompliance with the types of compliance requirements referred to above that could have a direct and material effect on a major federal program occurred. An audit includes examining, on a test basis, evidence about the College’s compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion on compliance for each major federal program. However, our audit does not provide a legal determination of the College’s compliance. Opinion on Each Major Federal Program In our opinion, the College complied, in all material respects, with the types of compliance requirements referred to above that could have a direct and material effect on each of its major federal programs for the year ended June 30, 2015. An independent member of Nexia International 3 Board of Trustees Community College of District of St. Louis, St. Louis County, Missouri Other Matters The results of our auditing procedures disclosed instances of noncompliance, which are required to be reported in accordance with OMB Circular A-133 and which are described in the accompanying schedule of findings and questioned costs as item 2015-002. Our opinion on each major federal program is not modified with respect to these matters. The College’s response to the noncompliance findings identified in our audit is described in the accompanying schedule of findings and questioned costs. The College’s response was not subjected to the auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response. Report on Internal Control Over Compliance Management of the College is responsible for establishing and maintaining effective internal control over compliance with the types of compliance requirements referred to above. In planning and performing our audit of compliance, we considered the College’s internal control over compliance with the types of requirements that could have a direct and material effect on each major federal program to determine the auditing procedures that are appropriate in the circumstances for the purpose of expressing our opinion on compliance for each major federal program and to test and report on internal control over compliance in accordance with OMB Circular A-133, but not for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, we do not express an opinion on the effectiveness of the College’s internal control over compliance. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. A material weakness in internal control over compliance is a deficiency, or combination of deficiencies in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance. Our consideration of internal control over compliance was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that were not identified. We did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses. However, we identified a certain deficiency in internal control over compliance, as described in the accompanying schedule of findings and questioned costs as item 2015-002 that we consider to be a significant deficiency. 4 Board of Trustees Community College of District of St. Louis, St. Louis County, Missouri The College’s response to the internal control over compliance findings identified in our audit is described in the accompanying schedule of findings and questioned costs. The College’s response was not subjected to the auditing procedures applied in the audit of compliance and, accordingly, we express no opinion on the response. The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the result of that testing based on the requirements of OMB Circular A-133. Accordingly, this report is not suitable for any other purpose. Report on Schedule of Expenditures of Federal Awards Required by OMB Circular A-133 We have audited the financial statements of the business-type activities and the remaining fund information of the College, as of and for the year ended June 30, 2015, and the related notes to the financial statements, which collectively comprise the College’s basic financial statements. We issued our report thereon dated January 28, 2016, which contained an unmodified opinion on the financial statements. Our audit was conducted for the purpose of forming an opinion on the financial statements that collectively comprise the basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by OMB Circular A-133 and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the basic financial statements as a whole. a CliftonLarsonAllen LLP Peoria, Illinois January 28, 2016 5 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year Ended June 30, 2015 Federal Grantor / Pass-Through Grantor/Program Title Contract Number CFDA Federal Number Expenditures NATIONAL AERONAUTICS AND SPACE ADMINISTRATION Education Training and Outreach NNX10AJ23G 43.006 NATIONAL SCIENCE FOUNDATION S-STEM Scholars DUE-1059607 47.076 71,951 98.001 98.001 11,843 370,473 UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT Passed-through: Georgetown University Scholarship for Ed & Economic Development SLCC-RX2050-705-12K Scholarship for Ed & Economic Development SLCC-RX2050-705-13J Total from Agency for International Development $ 24,412 382,316 UNITED STATES DEPARTMENT OF EDUCATION Student Financial Aid Cluster: Federal Supplemental Education Opportunity Grant Program Federal Work Study Program Federal Pell Grant Program Federal Direct Student Loans: Subsidized Loans Unsubsidised Loans PLUS Loans Total Student Financial Aid Cluster P007A142326 P033A142326 P063P141739 *84.007 *84.033 *84.063 770,469 549,298 33,679,640 P268K151739 P268K151739 P268K151739 *84.268 *84.268 *84.268 5,393,721 3,590,418 51,841 44,035,387 TRIO Cluster: Upward Bound Student Support Services Student Support Services Student Support Services Total TRIO Cluster P047A120670 P042A100624 P042A100326 P042A100777 84.047 84.042 84.042 84.042 309,357 212,925 270,888 228,564 1,021,734 Predominately Black Competitive Grant P382A110021 84.382A 197,329 Predominately Black Formula Grant P031P110022 84.031P 114,029 Child Care Parents In School grant P335A130018 84.335A 351,945 6 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year Ended June 30, 2015 Federal Grantor / Pass-Through Grantor/Program Title Contract Number UNITED STATES DEPARTMENT OF EDUCATION (CONTINUED) Passed-through Missouri Department of Elementary and Secondary Education: Title II - C Administration Title II - C Salaries Title II - C CP Transition and Retention Title II - C Prof Growth & Development Total Perkins IV CFDA Federal Number Expenditures 84.048 84.048 84.048 84.048 Adult Education Literacy 84.002 Total United States Department of Education $ 37,894 361,674 154,710 222,146 776,424 130,276 46,627,124 UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES Child Care Cluster: Improving the Quality of Child Care Early Childhood Child Care Early Childhood Technical Assistant Program Total Child Care Cluster Temporary Assistance for Needy Families Cluster: Passed-through DWD DWD-MO Customer Service Partnership Passed-through St. Louis Agency on Training and Employment: Slate Missouri Work Assistance Slate Missouri Work Assistance Total Temporary Assistance for Needy Families Cluster 93.575 93.575 93.596 11,999 8,911 13,908 34,818 42-20-46-14 *93.558 285,908 695.14 695.15 *93.558 *93.558 91,336 213,141 590,385 Total United States Department Health and Human Services 625,203 UNITED STATES DEPARTMENT OF AGRICULTURE Passed-through Missouri Department of Health and Human Services: Child Care Food Program 3MO300305-2013 7 10.558 25,716 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year Ended June 30, 2015 Federal Grantor / Pass-Through Grantor/Program Title Contract Number DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Passed-through the City of St. Louis, Missouri: Training for Tomorrow CFDA Federal Number Expenditures 14.228 ENVIRONMENTAL PROTECTION AGENCY Drinking Water Operator Training (DWOT) Environmental Job Training Grant 97736201 JT-97741801-0 66.424 66.815 Total Environment Protection Agency $ 74,302 46,143 74,687 120,830 UNITED STATES DEPARTMENT OF LABOR Passed-through Missouri Department of Economic Development/St. Louis Agency on Training and Employemnt: Slate- Launchcode Slate- Next Generation Career Ctr (Adult) Slate- Next Generation Career Ctr (Dislocted Workers) Slate- NGCC (Hostess NEG) Slate- NGCC (BIO) Slate -Youth County- MO-40 Job Driven NEG County- NGCC (Adult) County- NGCC (Dislocted Worker) 314-15 103.15 103.15 103-15 103.15 103.15 17.278 17.258 17.278 17.277 17.268 17.259 17.277 17.258 17.278 Total passed-through Missouri Department of Economic Development/St. Louis Agency on Training and Employemnt 138,550 116,989 58,324 883 10,053 106,415 76,060 825,855 426,699 1,759,828 Passed-through St. Louis Agency on Training and Employment: Bio St. Louis Staffing 427-15 Total WIA Cluster 17.268 63,905 1,823,733 8 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year Ended June 30, 2015 Federal Grantor / Pass-Through Grantor/Program Title Contract Number UNITED STATES DEPARTMENT OF LABOR (CONTINUED) Passed-through Metropolitan Communit College MoStem Wins CFDA Federal Number Expenditures TC-26470-14-60-A-29 17.282 100,659 TC-25098-13-60-A-29 17.282 1,182,324 Passed-through Ozark Technical Community College: MoHealthWINs Grant TC-22499-11-60-A-29 17.282 MoManufacturing Wins- STLCC TC-23785-12-60-A-29 17.282 1,002,981 MoManufacturing Wins- East Central TC-23785-12-60-A-29 17.282 541,614 MoManufacturing Wins- Linn State TC-23785-12-60-A-29 17.282 418,641 MoManufacturing Wins- Metropolitan CC TC-23785-12-60-A-29 17.282 636,167 MoManufacturing Wins- Mineral Area CC TC-23785-12-60-A-29 17.282 262,976 MoManufacturing Wins- North Central TC-23785-12-60-A-29 17.282 274,429 MoManufacturing Wins- Ozark Technical College TC-23785-12-60-A-29 17.282 341,888 MoManufacturing Wins- State Fair CC TC-23785-12-60-A-29 17.282 433,809 MoManufacturing Wins- St. Charles CC TC-23785-12-60-A-29 17.282 570,583 MoManufacturing Wins- MCCA TC-23785-12-60-A-29 17.282 314,825 MoManufacturing Wins- OTC-MCCA TC-23785-12-60-A-29 17.282 32,982 Missssippi River Consortium Total United States Department of Labor $ 758,286 8,695,897 TOTAL EXPENDITURES OF FEDERAL AWARD $ 56,647,751 * Major Program 9 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year Ended June 30, 2015 NOTE 1 - GENERAL The accompanying schedule of expenditures of federal awards (the schedule) presents the activity of all federal awards programs of the Community College District of St. Louis, St. Louis County, Missouri (the College) for the year ended June 30, 2015. The College’s reporting entity is defined in the summary of significant accounting policies in the College’s basic financial statements. Federal awards received directly from federal agencies as well as passed-through other government agencies are included on the schedule. NOTE 2 - BASIS OF ACCOUNTING AND RELATIONSHIP TO FEDERAL FINANCIAL REPORTS The accompanying schedule is presented using the accrual basis of accounting. Some federal financial reports are filed on the cash basis of accounting. NOTE 3 - ADDITIONAL INFORMATION As of and during the year ended June 30, 2015, the College did not receive any noncash federal assistance, federal insurance, or federal loans or loan guarantees. In addition, the College did not pass through any federal assistance to subrecipients. NOTE 4 - LOAN PROGRAMS The College participates in the Federal Direct Student Loan Program, which provides federal loans directly to the students rather than through private lending institutions. The College is responsible only for the origination of the loan (e.g., determining student eligibility and disbursing loan proceeds to the borrower). The Direct Loan Servicer is then responsible for the overall servicing and collection of the loan. Accordingly, these loans are not included in the College's financial statements. The amount reported on the schedule of expenditures of federal awards for the loan program represents the total value of the loans awarded and paid to the College's students during the year ended June 30, 2015. 10 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS NOTE 5 - SUMMARY OF CFDA TOTALS CFDA Number Total Expenditures 10.558 14.228 17.258 17.259 17.268 17.277 17.278 17.282 43.006 47.076 66.424 66.815 84.002 84.007 84.031P 84.033 84.042 84.047 84.048 84.063 84.268 84.335A 84.382A 93.558 93.575 93.596 98.001 $ 25,716 74,302 942,844 106,415 73,958 76,943 623,573 6,872,164 24,412 71,951 46,143 74,687 130,276 770,469 114,029 549,298 712,377 309,357 776,424 33,679,640 9,035,980 351,945 197,329 590,385 20,910 13,908 382,316 TOTAL $ 56,647,751 This information is an integral part of the accompanying schedule. 11 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ended June 30, 2015 Section I - Summary of Auditors’ Results Financial Statements Type of auditors’ report issued: Unmodified Internal control over financial reporting: Material weakness(es) identified? Significant deficiencies identified that are not considered to be material weaknesses? Noncompliance material to financial statements noted? x Yes No Yes Yes None Reported No Yes No Federal Awards Internal control over major programs: Material weakness(es) identified? Significant deficiencies identified that are not considered to be material weakness(es)? Type of auditors’ report issued on compliance for major programs: Any audit findings disclosed that are required to be reported in accordance with section 510(a) of OMB Circular A-133? x Yes None Reported Unmodified x Yes No Identification of major programs: CFDA Number(s) TANF CLUSTER 93.558 SFA CLUSTER 84.007 84.033 84.063 84.268 Name of Federal Program or Cluster Division of Workforce Development - Missouri Customer Service Partnership & SLATE Missouri Work Assistance Federal Supplemental Education Opportunity Grant Program Federal Work Study - Student Financial Assistance Cluster Federal Pell Grant - Student Financial Assistance Cluster Federal Direct Student Loans - Student Financial Assistance Cluster Dollar threshold used to distinguish between type A and type B programs: $378,371 Auditee qualified as low-risk auditee? Yes 12 x No COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ended June 30, 2015 Section II - Financial Statement Findings Finding No. 2015-001 - Financial Statement Preparation Condition: The College did not have sufficient internal controls over the reporting requirements of Government Accounting Standards Board (GASB) Statements No. 68 and 71 on pension accounting. During the audit we noted the College did not properly record the pension liability and related assets, deferred outflows and inflows of resources, expenditures and restatement of net position. An audit adjustment was required to reflect the proper amounts in the financial statements. In addition, the related financial statement disclosures and required supplementary information were not properly completed and presented in accordance with accounting principles generally accepted in the United States. Criteria or specific requirement: Management is responsible for establishing and maintaining internal controls and for the fair presentation of the financial statements including the related disclosures and required supplementary information in conformity with accounting principles generally accepted in the United States. Effect: The financial statements were materially misstated prior to the audit adjustment and were not detected by the College’s internal controls. Cause: College management stated that their lack of knowledge in the area, caused by a number of factors, but primarily by the controller being new to GASB and the departure of the CFO at the beginning of the audit process, led to the breakdown in internal control over the preparation and review of the financial statements. This was fully disclosed to the auditors in September. The College asked for assistance with the required transactions, reporting and disclosures. Recommendation: We recommend the College obtain the necessary level of knowledge to properly apply the GASB accounting principles. College Response: The College has taken efforts to obtain additional training for the accounting staff on the new GASB statements and the accounting treatment and reporting that is required. This includes obtaining and developing tools and processes to ensure compliance will all aspects of these new GASB statements. 13 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ended June 30, 2015 Section III - Federal Award Findings and Questioned Costs Finding 2015-002 - Student Financial Aid Cluster Special Tests and Provisions United States Department of Education Federal Supplemental Educational Opportunity Grants – 84.007 Federal Work-Study Program – 84.033 Federal Pell Grant Program – 84.063 Federal Direct Student Loans – 84.268 Condition: During our testing, we noted the National Student Loan Data Systems (NSLDS) roster returned yielded error reports that were not corrected and resubmitted within the required 10 days. The College utilizes the National Student Clearinghouse (NSC) as a third party provider in order to submit student information to NSLDS. NSC had software conversion issues that failed in monitoring and correcting submission errors. However, it is possible for the College to create an Enrollment Reporting Summary Report after reporting student status changes on NSLDS, which would have detected these types of errors. Criteria: Federal regulation requires enrollment status for each student be reported accurately to NSLDS. In addition, regulations require that an institution make necessary corrections and return the records within 10 days for any roster files that don’t pass the NSLDS enrollment reporting edits. Questioned Costs: No questioned costs in the current year. Effect: The College did not update student enrollment statuses correctly or timely to NSLDS. Cause: Management was not aware of the NSC software conversion issues and did not utilize the Enrollment Reporting Summary Report to determine if student status changes were being updated accurately and timely. Recommendation: We recommend that the College put a process in place to ensure enrollment statuses are accurately and timely reported to NSLDS. The system should include understanding if and when the NSC third party servicer has corrected the failed software programming. 14 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS, ST. LOUIS COUNTY, MISSOURI SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ended June 30, 2015 Section III - Federal Award Findings and Questioned Costs Finding 2015-002 - Student Financial Aid Cluster Special Tests and Provisions (Continued) College Response: The College will continue to utilize the National Student Clearinghouse (NSC) as a third party provider in order to submit student information to NSLDS. Enrollment data is submitted monthly. The College will verify future submissions have been processed by the NSC within 5 days of our submission. If the file has not been processed within this time frame, we will bring this to the attention of our NSC contact as well as the College’s Management/Director of Financial Aid. 15 COMMUNITY COLLEGE DISTRICT OF ST. LOUIS ST. LOUIS COUNTY, MISSOURI SCHEDULE OF STATUS OF PRIOR FINDINGS Year Ended June 30, 2015 None. 16