Audit 13479

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023– 002 – Federal Work Study (FWS) Over Award Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.033 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per ED regulations an institution may only award FWS employment to a student if the award, combined with the other estimated financial assistance the student receives, does not exceed the student’s financial aid 34 CFR 673.5(a). Condition: In our sample of 40 students tested, three students were over awarded through the receipt of FWS employment. Questioned Costs: $4,230 Context: Three students out of a sample of 40 were provided with FWS employment when their financial need was already met. Cause: These students were over awarded during the award packaging process and resulted from human error. Effect: The College is not in compliance with the federal regulations. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures when packaging students for FWS. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023 – 001 – National Student Loan Data Systems (NSLDS) Enrollment Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.038, 84.063, 84.268 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the College to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, the school may provide the date on that roster file. 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. ED requires the University to report changes in enrollment status within 30 or 60 days that the College determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned Costs: None Context: During our testing, we noted the following out of our sample of 17 students tested: - 1 student’s enrollment status and effective date was incorrectly reported at the campus level and they were not timely reported to NSLDS. - 3 student’s effective date reported to NSLDS did not agree to the effective date of per the College at the campus level. - 10 student’s enrollment status and effective date reported to NSLDS at the program level did not agree to the status and effective date reported to NSLDS at the campus level. Cause: Enrollment information was not properly transmitted to NSLDS. Effect: Student enrollment information is not being accurately reported to the NSLDS. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: See attached corrective action plan.

2023– 002 – Federal Work Study (FWS) Over Award Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.033 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per ED regulations an institution may only award FWS employment to a student if the award, combined with the other estimated financial assistance the student receives, does not exceed the student’s financial aid 34 CFR 673.5(a). Condition: In our sample of 40 students tested, three students were over awarded through the receipt of FWS employment. Questioned Costs: $4,230 Context: Three students out of a sample of 40 were provided with FWS employment when their financial need was already met. Cause: These students were over awarded during the award packaging process and resulted from human error. Effect: The College is not in compliance with the federal regulations. Repeat Finding: No. Auditors’ Recommendation: The College should review its policies and procedures when packaging students for FWS. Views of Responsible Officials: See attached corrective action plan.