Audit 10337

FINDING 2023-001 Federal Program Information: Research and Development Cluster (ALN: 47.047) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): H. Period of Performance - Per Uniform Guidance, (2 CFR sections 200.308), the auditee may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Condition: During our testing of research and development expenditures, we noted the following exception: • For 1 of the 25 selected research and development cluster grants had certain expenditures reported on the 2023 schedule of expenditures of federal awards that were incurred subsequent to the period of performance end date. Cause: Administrative oversight with respect to period of performance requirements. Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure compliance with period of performance requirements. Questioned Costs: $40,147 Context: We tested a sample of 25 research and development cluster grants and found 1 exception as noted in the condition with a total impact of $40,147. This is a condition identified per review of the School’s compliance with specific requirements using a statistically valid sample. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the School enhance its policies and procedures to ensure that expenditures are incurred and recorded during each grants’ respective performance period. Views of Responsible Officials and Planned Corrective Actions: We agree. The expenditures were reported on the schedule of expenditures for federal awards subsequent to the period of performance end date. These funds were not charged to the agency and are considered cost share for the grant as the work on the grant continued past the grant end date. We will review our grant close-out procedures to ensure that grants are closed out in a timely manner based on the grant end date preventing subsequent charges to the grant award.

FINDING 2023-002 Federal Program Information: Student Financial Assistance Cluster (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The School is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the School becomes aware of the change in enrollment status. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Additionally, Institutions are responsible for accurately reporting the significant data elements that ED considers high risk under the Program-Level Record on the NSLDS website. Condition: During our testing of student enrollment reporting, we noted the following exceptions: • For 8 of 25 students selected for testing, the School failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe. • Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe. • For 1 of 25 selected students, there was no Program-Level Record on the NSLDS website to verify the school accurately reported the required significant data elements required by the ED. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to all aspects of enrollment reporting. Context: We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2022-002 in the 2022 report. Recommendation: We recommend that the School enhance its policies and procedures to ensure that all status changes are submitted to the NSLDS website within the required timeframe, error records are corrected and submitted timely and all required data elements are reported on the NSLDS website. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that status changes must be submitted, and errors must be corrected in the National Student Clearinghouse and NSLDS in a timely manner. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. Additionally, we will implement the following processes: • An automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. • Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. Additionally, all student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems.

FINDING 2023-003 Federal Program Information: Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the School must timely and accurately post their required quarterly reports to School’s website and must submit an annual report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Condition: During our testing of quarterly progress reports, we noted the following exceptions: • For 1 of 4 quarterly progress reports, the School did not submit the report within the required timeframe. • For 4 of the 4 quarterly reports and the annual report, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records. Cause: Administrative oversight with respect to reporting compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports. Questioned Costs: None. Context: We tested all 4 quarterly progress reports and found 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School develop policies and procedures over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that annual reports must be submitted to the agency and quarterly reports uploaded on our website accurately and in a timely manner. We will review our procedures to ensure proper monitoring to ensure report submissions are complete, accurate, and prepared in accordance with the established requirements. We are moving forward to separate grants and contract post-awards from Finance to the newly established Research Administration area. With this restructuring of the department and staffing, we are also establishing a compliance area that will be charged with ensuring reporting requirements are completed based on the required agency guidelines. This new structure will strengthen our review and monitoring of grant compliance. Additionally, review and monitoring of reports will take place to ensure timely and accurate submission for the entire grants and contract portfolio.

FINDING 2023-003 Federal Program Information: Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the School must timely and accurately post their required quarterly reports to School’s website and must submit an annual report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Condition: During our testing of quarterly progress reports, we noted the following exceptions: • For 1 of 4 quarterly progress reports, the School did not submit the report within the required timeframe. • For 4 of the 4 quarterly reports and the annual report, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records. Cause: Administrative oversight with respect to reporting compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports. Questioned Costs: None. Context: We tested all 4 quarterly progress reports and found 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School develop policies and procedures over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that annual reports must be submitted to the agency and quarterly reports uploaded on our website accurately and in a timely manner. We will review our procedures to ensure proper monitoring to ensure report submissions are complete, accurate, and prepared in accordance with the established requirements. We are moving forward to separate grants and contract post-awards from Finance to the newly established Research Administration area. With this restructuring of the department and staffing, we are also establishing a compliance area that will be charged with ensuring reporting requirements are completed based on the required agency guidelines. This new structure will strengthen our review and monitoring of grant compliance. Additionally, review and monitoring of reports will take place to ensure timely and accurate submission for the entire grants and contract portfolio.

FINDING 2023-004 Federal Program Information: Student Financial Aid Cluster (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management – Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds for the Federal Direct Student Loan Program. Cause: Administrative oversight with respect to cash management compliance requirements as it relates to the Federal Direct Student Loan Program. Effect or Potential Effect: The School is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds. Questioned Costs: None. Context: We examined all draws of Title IV aid and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School enhance its policies and procedures to ensure that excess cash balances are eliminated timely. Views of Responsible Officials and Planned Corrective Actions: We understand the requirement of disbursing Title IV funding to eligible students and parents and the requirement to make disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds and eliminating excess cash balance within the next 7 calendar days. In this case, the School received funds from the student from unknown sources, and the School submitted the funds to the ED on behalf of the student at the student’s request to lower outstanding educational debt. We discuss the importance of lowering education debt during our debt counseling sessions and encourage students to return funds not needed due to subsequent scholarships or family support. We will begin requiring students to submit the return themselves to the ED by providing them the ED’s instructions.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-001 Federal Program Information: Research and Development Cluster (ALN: 47.047) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): H. Period of Performance - Per Uniform Guidance, (2 CFR sections 200.308), the auditee may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. Condition: During our testing of research and development expenditures, we noted the following exception: • For 1 of the 25 selected research and development cluster grants had certain expenditures reported on the 2023 schedule of expenditures of federal awards that were incurred subsequent to the period of performance end date. Cause: Administrative oversight with respect to period of performance requirements. Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure compliance with period of performance requirements. Questioned Costs: $40,147 Context: We tested a sample of 25 research and development cluster grants and found 1 exception as noted in the condition with a total impact of $40,147. This is a condition identified per review of the School’s compliance with specific requirements using a statistically valid sample. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the School enhance its policies and procedures to ensure that expenditures are incurred and recorded during each grants’ respective performance period. Views of Responsible Officials and Planned Corrective Actions: We agree. The expenditures were reported on the schedule of expenditures for federal awards subsequent to the period of performance end date. These funds were not charged to the agency and are considered cost share for the grant as the work on the grant continued past the grant end date. We will review our grant close-out procedures to ensure that grants are closed out in a timely manner based on the grant end date preventing subsequent charges to the grant award.

FINDING 2023-002 Federal Program Information: Student Financial Assistance Cluster (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Enrollment Reporting – The School is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or drop to less than half-time status during the fiscal year within 30 days of the date the School becomes aware of the change in enrollment status. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. According to the Federal Student Aid Handbook, schools are required to certify enrollment for all students who are included on their roster file scheduled at least every two months, and within 15 days of the date that NSLDS sends a roster file to the school or its third-party servicer. Any errors identified and returned by NSLDS in an Error/Acknowledgement file should be corrected and resubmitted within 10 days. Additionally, Institutions are responsible for accurately reporting the significant data elements that ED considers high risk under the Program-Level Record on the NSLDS website. Condition: During our testing of student enrollment reporting, we noted the following exceptions: • For 8 of 25 students selected for testing, the School failed to submit the student’s graduated or withdrawn status to NSLDS within the required timeframe. • Multiple error records identified in Error/Acknowledgment files were not corrected within the required timeframe. • For 1 of 25 selected students, there was no Program-Level Record on the NSLDS website to verify the school accurately reported the required significant data elements required by the ED. Cause: Administrative oversight with respect to enrollment reporting requirements. Effect or Potential Effect: The School is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to all aspects of enrollment reporting. Context: We tested a sample of 25 students and found exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: This is a repeat finding from prior year. This was reported as finding 2022-002 in the 2022 report. Recommendation: We recommend that the School enhance its policies and procedures to ensure that all status changes are submitted to the NSLDS website within the required timeframe, error records are corrected and submitted timely and all required data elements are reported on the NSLDS website. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that status changes must be submitted, and errors must be corrected in the National Student Clearinghouse and NSLDS in a timely manner. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. Additionally, we will implement the following processes: • An automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. • Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. Additionally, all student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems.

FINDING 2023-003 Federal Program Information: Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the School must timely and accurately post their required quarterly reports to School’s website and must submit an annual report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Condition: During our testing of quarterly progress reports, we noted the following exceptions: • For 1 of 4 quarterly progress reports, the School did not submit the report within the required timeframe. • For 4 of the 4 quarterly reports and the annual report, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records. Cause: Administrative oversight with respect to reporting compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports. Questioned Costs: None. Context: We tested all 4 quarterly progress reports and found 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School develop policies and procedures over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that annual reports must be submitted to the agency and quarterly reports uploaded on our website accurately and in a timely manner. We will review our procedures to ensure proper monitoring to ensure report submissions are complete, accurate, and prepared in accordance with the established requirements. We are moving forward to separate grants and contract post-awards from Finance to the newly established Research Administration area. With this restructuring of the department and staffing, we are also establishing a compliance area that will be charged with ensuring reporting requirements are completed based on the required agency guidelines. This new structure will strengthen our review and monitoring of grant compliance. Additionally, review and monitoring of reports will take place to ensure timely and accurate submission for the entire grants and contract portfolio.

FINDING 2023-003 Federal Program Information: Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – The School is required to comply with the requirements of Reporting associated with its federal awards. According to the Uniform Guidance, the School must timely and accurately post their required quarterly reports to School’s website and must submit an annual report covering calendar year expenditures. Amounts reported should agree to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Condition: During our testing of quarterly progress reports, we noted the following exceptions: • For 1 of 4 quarterly progress reports, the School did not submit the report within the required timeframe. • For 4 of the 4 quarterly reports and the annual report, certain information submitted to the funding agency or posted to the School’s website was not accurately presented and did not reconcile to the School’s records. Cause: Administrative oversight with respect to reporting compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to the reporting compliance requirements and timely submission of reports. Questioned Costs: None. Context: We tested all 4 quarterly progress reports and found 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School develop policies and procedures over the applicable reporting requirements to ensure compliance with federal regulations as well as the grant agreements. Views of Responsible Officials and Planned Corrective Actions: We agree. We understand that annual reports must be submitted to the agency and quarterly reports uploaded on our website accurately and in a timely manner. We will review our procedures to ensure proper monitoring to ensure report submissions are complete, accurate, and prepared in accordance with the established requirements. We are moving forward to separate grants and contract post-awards from Finance to the newly established Research Administration area. With this restructuring of the department and staffing, we are also establishing a compliance area that will be charged with ensuring reporting requirements are completed based on the required agency guidelines. This new structure will strengthen our review and monitoring of grant compliance. Additionally, review and monitoring of reports will take place to ensure timely and accurate submission for the entire grants and contract portfolio.

FINDING 2023-004 Federal Program Information: Student Financial Aid Cluster (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): C. Cash Management – Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)). Condition: During our cash management testing, we noted multiple instances during the fiscal year where funds drawn were held in excess of the allowable time frame and/or allowable thresholds for the Federal Direct Student Loan Program. Cause: Administrative oversight with respect to cash management compliance requirements as it relates to the Federal Direct Student Loan Program. Effect or Potential Effect: The School is not properly following policies and procedures in place to ensure that compliance is maintained with cash management requirements and the timely return of funds. Questioned Costs: None. Context: We examined all draws of Title IV aid and identified multiple instances of cash held in excess of the allowable time frame and/or allowable thresholds as noted in the condition. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School enhance its policies and procedures to ensure that excess cash balances are eliminated timely. Views of Responsible Officials and Planned Corrective Actions: We understand the requirement of disbursing Title IV funding to eligible students and parents and the requirement to make disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds and eliminating excess cash balance within the next 7 calendar days. In this case, the School received funds from the student from unknown sources, and the School submitted the funds to the ED on behalf of the student at the student’s request to lower outstanding educational debt. We discuss the importance of lowering education debt during our debt counseling sessions and encourage students to return funds not needed due to subsequent scholarships or family support. We will begin requiring students to submit the return themselves to the ED by providing them the ED’s instructions.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.

FINDING 2023-005 Federal Program Information: Research and Development Cluster (ALN: Various), The National COVID-19 Resiliency Network: Mitigating the Impact of COVID-19 on Vulnerable Populations (ALN: 93.137), Community‐Based Workforce to Build COVID‐19 Vaccine Confidence (ALN: 93.011) and Education Stabilization Fund Higher Education Emergency Relief Fund (ALN: 84.425E, 84.425J) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation) B. Allowable Cost/Cost Principles - Federal grant requirements, § 200.430, provide that salaries and wages charged to federal awards must be based on records that accurately reflect the work performed; be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated; be incorporated into the official records of the institution; reasonably reflect the total activity for which the employee is compensated; and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award. Condition: During our testing of expenditures, we noted the following exceptions: • For 7 of 100 selected employees, level of effort certifications were not available to support the payroll costs charged to the federal program. Cause: Lack of administrative oversight with respect to allowable cost/cost principles compliance requirements. Effect or Potential Effect: The School does not have policies and procedures in place to ensure that compliance is maintained with respect to supporting payroll costs charged to the federal programs. Questioned Costs: Indeterminable. Context: We tested a sample of 100 expenditures across four major programs and noted 4 exceptions as noted in the condition. This is a condition identified per review of the School’s compliance with specified requirements using a statistically valid sample. Identification as a Repeat Finding: No similar finding was identified during the prior year. Recommendation: We recommend that the School adhere to its policies and procedures over the applicable compliance requirements of allowable costs/cost principles requirements to ensure that the School is appropriately monitoring level of effort reporting in a timely manner. Views of Responsible Officials and Planned Corrective Actions: We experienced a system glitch resulting in records that remained in validation tables and did not move to the process reporting tables which prevented proper reporting of work hours performed. The system did not generate the required certification reports to allow the selected employee to certify their effort. We are reviewing our processes to implement an automated comparison reports of individual employees paid from federal grants and the system generated effort certification report to ensure that the system generates the required effort report to allow the employee to properly certify their effort. We will also ensure that all employees approve/certify actual time worked allotted to federal funds within our time and attendance system to provide another level of certification. This report will be produced quarterly to ensure that system errors are corrected before the required semiannual effort reporting requirement.