Student Success & Support Program (SSSP): an Internal Auditor’s Perspective Nikhil Bassi, CPA MST Internal Auditor (Staff) Contra Costa Community College District Friday May 6, 2016

Overview A.Introduction & Criteria B.CDAM Requirement 429 C.Tips and control considerations for SSSP audits, along with control observations.

A. Introduction The Seymour-Campbell Student Success Act of 2012 (Lowenthal, SB 1456) requires California Community Colleges to provide core student services to lay a foundation for student achievement and successful completion of educational goals. The program of services funded through this Act are known and cited as the Student Success and Support Program (SSSP); formerly Matriculation. The mission of the SSSP is to increase community college students’ access and success by providing effective core services.

A. Introduction The purpose of the SSSP is to ensure that all students promptly define their educational and career goals, persist to the next academic term, and achieve their educational objectives in a timely manner. Prior legislation, the Seymour-Campbell Matriculation Act of 1986, established the matriculation process for new and continuing students in credit courses.

A. Introduction Core services: Orientation Assessment Educational Plan Counseling & Follow-up services

A. SSSP Process

A. Funding In accordance with SB 1456, the formula to allocate funds for the program includes the following elements: The number of students to receive services at each college. The number of students who received orientation; assessment; counseling, advising, and other educational planning services; and follow up for at-risk students.

A. District Match SB 1456 requires districts to contribute matching funds for SSSP. In the past, Title 5, Section required that each dollar of state credit SSSP funds be matched by three dollars of other district resources devoted to the SSSP. This was changed to 2:1 for A memo was issued by the Chancellor’s Office on December 17, 2015 establishing the matching guidelines to 1:1. Therefore, the current match requirement for state credit and non-credit SSSP funds is 1:1.

A. Reporting Requirements Student Success and Support Program Plans and Budget Plans Mid-Year Report -- Declaration of Unused Credit and Noncredit SSSP Funds Management Information System (MIS) data reporting 30 days after the end of each term; SSSP Year-End Expenditures Report (Credit and Noncredit)

A. Allowable Expenditures (must be SSSP related) SSSP Program Director / Coordinator & Staff Office Supplies & Postage Publications & Outreach Materials (SSSP Related) In-state travel & training (out-of-state travel is allowable on a case by case basis if it is SSSP related; ideally pre-approved) Computer hardware / software / equipment Food & Beverages (SSSP Related) Counseling, Advising, and other Student Education Planning services Follow-up services

A. Allowable Expenditures Orientation Services Assessment for Placement Services Research, Admissions, and Transfer functions related to core SSSP services

A. Unallowable Expenses Construction Gifts Stipends for students Office furniture Other staff salaries & benefits Political or professional dues, memberships, contributions Rental of off-campus space Legal / audit expenses Indirect costs

A. Unallowable Expenses Unrelated travel costs Vehicles Clothing Courses (expenses for delivering courses that generate FTES) Admissions and Records Offices Research Offices

A. Expenditures for District Match In addition to the allowable expenditure categories mentioned, Districts may also count expenditures for matching funds that were allowable under Matriculation as of Admissions & Records Transfer & Articulation services Career services Institutional Research Unallowable expenditures for District match: Unallowable expenditures mentioned Categorical program expenditures – e.g. EOPS, DSPS, Student Equity.

B. CDAM Requirement 429 -Compliance All students should be receiving required services, unless they have been exempted and reported as such to the Chancellor's Office. The CCCCO has determined that districts must provide a one-to-one funding match for credit courses AND noncredit programs. Noncredit programs must submit a program certification form annually to receive SSSP funds. SSSP funds may only be used for expenditures as stated in the SSSP handbook (pages ) College match may only be included for expenditures as stated in the SSSP handbook (pages 4.12 – 4.14)

B. CDAM Requirement 429 –Audit Procedures Test student counts for core services Test revenues and expenditures of the Student Success and Support Program for compliance with applicable criteria Verify that noncredit programs using SSSP funds submitted a program certification for the current year. Verify that college submitted program plans and budget plans for CCCCO approval. Verify that college submitted other program required forms to the CCCCO (certifications, mid-year reports, year-end expenditure reports). Verify that the districts have met the match requirements for the Student Success and Support Program

B. Program Plan Template

B. Mid-year Expenditure report

B. Year-end Expenditure report & Budget Plan Template

B. Student Counts Confirmed reports existed in our ERP system to identify student counts related to core SSSP services. Colleges enter services into SARS (appointment scheduling / tracking system), which interfaces with our ERP system. This info is then extracted and prepared for reports sent to the Chancellor’s Office, Management Information Unit. Reports are prepared by and integrity of the underlying data transmitted across systems is assured by our District Office Database Administrator, who serves as MIS coordinator.

C. Control Considerations & tips for SSSP Audits 1.Are expenses allowable under applicable criteria? Are segregation of duties and proper authorization procedures observed? 2.Are there systems and reports in place to track student counts and fulfill MIS reporting obligations? 3.Are colleges filing reports as required with the Chancellor’s Office? Are expenditure and District Match obligations met?

C. Control Considerations & tips for SSSP Audits 1.Does the college have adequate documentation to justify salary expenditures for staff charged to SSSP funds? 2.Were expenditures made in the applicable time period (considering 6 month extension to 12/31 for the previous fiscal year)? 3.Does the College / District have non-credit SSSP funds? If so, are applicable match requirements and reporting requirements followed?

C. Control Observations 1.SSSP Coordinators are integral to help auditors understand the College’s SSSP plan, strategic plan, student equity plan. 2.SSSP Coordinators are key – to help explain charges that are SSSP as compared to Categorical programs. Supporting documents should be clear as to which charges are allocated to SSSP and why. 3.SSSP Coordinators should be very familiar with their charges. In particular salary charges for reallocation of time, and justification of how expenditures support the overall goals of SSSP. Typically, one might see creation of new positions or hiring of additional staff. This would avoid supplanting and support SSSP goals.

Resources & Criteria CDAM 2016 Requirement 429 Chancellor’s Office SSSP Handbook & Training / Webinars for SSSP Coordinators (also resources on CO web site) Education Code Sections – (Matriculation & Student Equity) Title 5, Sections – (Student Success & Support Program)