Audit 13897

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 10 disbursements to students out of a population of 136 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – Yes, 2022-004 Recommendation – We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students. Views of responsible officials and planned corrective actions – The University shall establish and maintain a documented policy outlining the allocation of HEERF student aid portion monies to students.

2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 10 disbursements to students out of a population of 136 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – Yes, 2022-004 Recommendation – We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students. Views of responsible officials and planned corrective actions – The University shall establish and maintain a documented policy outlining the allocation of HEERF student aid portion monies to students.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P222403, P268K232403 Award Year: 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2022-010   Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P222403, P268K232403 Award Year: 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2022-010   Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Program Name: Federal Perkins Loan Program Award Year: 2022-23 Criteria – In accordance with 34 CFR 674.19(d) the institutional must maintain program and fiscal records of all Perkins funds since the most recent Fiscal Operations Report (FISAP) was submitted and reconcile this information at least monthly. Condition/context – The University could not provide the required reconciliations as required by 34 CFR section 674.19(d). Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of a lack of understanding of the compliance requirements for Perkins program and fiscal records. The University is unable to provide support that the program and fiscal records of all the Perkins funds reconciles to the most recent FISAP. Repeat finding – No Recommendation – We recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans was properly liquidated. Views of responsible officials and planned corrective actions – To ensure the Perkins loan portfolio was correctly liquidated, the University will reconcile the data with the most current FISAP filed.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Compensation costs are allowable to the extent they satisfy requirements of 2 CFR section 200.430, and the total compensation for individual employees is determined and supported as provided in 2 CFR section 200.430(i), including charges to Federal awards for salaries and wages be based on records that accurately reflect the work performed. Condition/context – A sample of 17 employees out of a population of 32 employees whose compensation was charged to the awards was selected. Of the 17 samples selected we found 10 employees who either had no records to support the actual allocation of time that was charged to each award or the amount allocated to the award did not agree to the time and effort reporting. The personnel action form that is completed upon hire indicated the allocation of time worked in some instances, however in accordance with 2 CFR section 200.430 (i)(1)(viii) estimates determined before the services are performed do not qualify as support for charges to Federal awards. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable Cause/effect – The University does not have the proper controls in place to ensure time and effort reporting is completed or completed accurately. The lack of records supporting the actual allocation of time charged increases the risk of unallowable compensation costs being charged to the federal award. Repeat finding – Yes, 2022-002 Recommendation – We recommend the University implement an internal control policy that requires employees whose compensation is charged to a federal award complete time and effort reporting to accurately reflect the work performed on each federal award and ensure supporting documentation is maintained for those who do charge time and agrees to amount allocated to the award. Views of responsible officials and planned corrective actions – Heritage University will implement a new internal control policy that requires employees whose compensation is charged to federal awards to complete time and effort to accurately reflect the work performed on each federal award. Heritage University is using the time and effort forms to allocate the correct hours to each federal award during the payroll process period. Each pay period an employee must fill out the time and effort to show actual hours worked. The form is signed by the employee and supervisor before turning it in to the payroll department. An email will be sent out to all employees outlining the new process required by employees whose hours are charged to a federal award.

2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 10 disbursements to students out of a population of 136 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – Yes, 2022-004 Recommendation – We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students. Views of responsible officials and planned corrective actions – The University shall establish and maintain a documented policy outlining the allocation of HEERF student aid portion monies to students.

2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – In accordance with the Funding Certification and Agreement for the Emergency Financial Aid Grants to Students institutions must have a documented plan to distribute funds to students. Condition/context – A sample of 10 disbursements to students out of a population of 136 disbursements to students was selected. A documented plan for distribution of funds to students was requested, however the University did not have a documented plan. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The University did not have the controls in place to formerly approve a plan for distributions of funds that was documented and circulated to the University. The lack of a documented plan for distribution of funds to students increases the risk that funds were inappropriately disbursed to students at the wrong amounts. In addition, it increases the risk that the disbursements were not equitable across the student population. Repeat finding – Yes, 2022-004 Recommendation – We recommend the University adopt a policy that is formally approved and retained indicating how HEERF student aid portion funds are to be distributed to students. Views of responsible officials and planned corrective actions – The University shall establish and maintain a documented policy outlining the allocation of HEERF student aid portion monies to students.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-004 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.425E, 84.425F, 84.425L Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Student Aid Portion, Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Higher Education Emergency Relief Funds (HEERF) Minority Serving Institutions (MSIs) Federal Award Number: P425E200777, P425F201298, P425L200234 Award Year: 2022-23, 2021-22, 2020-21 Criteria – Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds under HEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition/context – A sample of 5 special reports from the population of 5 special reports was selected. Two of the quarterly reports were not posted timely. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting. Three of the four quarterly reports were corrected based on the audit procedures performed, the University did not properly identify these as “corrected” upon posting to the University website. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – Due to the turnover in the business office, the University did not post its quarterly reports timely and was unable to provide consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for data reported and documented review results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-005 Recommendation – We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report be posted to the University’s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature and date. Views of responsible officials and planned corrective actions – Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY21, FY22 & FY23 on the University’s website by quarter. Going further, it will be the Grant accountant’s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Criteria – Under 2 CFR section 200.329 non-Federal entities are required to submit performance reports at the interval required by the Federal awarding agency. Condition/context – The University was unable to provide documentation supporting the reporting requirements for the award. The reporting requirements would include the type of report to be submitted, time period covered by the report and due date of the report. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/Effect – The University does not have a centralized process for tracking report due dates. The lack of support for required due dates results in a material noncompliance with the reporting compliance requirement. Repeat finding – Yes, 2022-007 Recommendation – We recommend the University create an internal control to obtain reporting requirements for each award received by the University. We recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Views of responsible officials and planned corrective actions – The University will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time.

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P222403, P268K232403 Award Year: 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2022-010   Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P222403, P268K232403 Award Year: 2022-23, 2021-22 Criteria – The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the University’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record and Program-Level Record that ED considers high risk, which includes the student's program as per the Classification of Instructional Programs (CIP) code, and the student's status change Effective Date. Condition/context – We selected a sample of 42 students out of a population of 626 who had received Federal aid and were reported to NSLDS during the fiscal year. We compared the significant data elements under the Campus-Level and Program-Level Records that ED considers high risk as reported to NSLDS to the data included in the student's academic records, other institutional records, and the withdrawal or graduation date per the University’s records. We noted exceptions with 4 out of the 42 students tested. Two students were not reported as withdrawn to NSLDS. One student was not reported as graduated to NSLDS. One student was reported to NSLDS, however the dates did not match the institutional records. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and oversight of the process. This resulted in incomplete and inaccurate reporting of the information to NSLDS. The enrollment information reported to NSLDS is utilized by ED, the Direct Loan program, lenders, and other institutions to determine in-school status. Repeat finding – Yes, 2022-010   Recommendation – We recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. We also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Views of responsible officials and planned corrective actions – The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-008 – Equipment and Real Property Management – Material Weakness in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23 Criteria – Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) for real property and equipment management. 2 CFR 200.313(d)(1) requires that property records must be maintained that include, among other things, description of the property, source of funding for the property and percentage of Federal participation in the project costs for the Federal award under which the property was acquired. 2 CFR 200.313(d)(2) states that a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition/context – We selected a sample of 5 equipment purchases out of a population of 25 equipment purchases made during the year. The University did not maintain the required property records for any of the purchases. In addition, the University did not perform a physical inventory for those purchases in the last two years. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of lack of controls and an antiquated equipment tracking system. The University is unable to satisfy the requirement that they maintain proper records for equipment and adequately safeguards and maintains equipment. Repeat finding – No Recommendation – We recommend the University update their equipment tracking system to allow the University to identify assets purchased with federal money. In addition, we recommend the University perform a physical inventory of its fixed asset at least once every two years. Views of responsible officials and planned corrective actions – In order to track assets acquired with federal funds, the university will update its equipment tracking system and will conduct a physical inventory of its fixed assets at least every two years.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.379, 84.268, 84.007 Federal Program Name: Federal Pell Grant Program, Teacher Education Assistance for College and Higher Education, Federal Direct Student Loans, Supplemental Educational Opportunity Grant Federal Award Number: P063P222403, P379T232403, P268K232403, P007A224364 Award Year: 2022-23 Criteria – In accordance with 34 CFR 668.22 when a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student’s withdrawal date. Condition/context – We selected a sample of 3 official and 2 unofficial withdrawals from a population of 38 total withdrawals. One student tested was processed as an official withdrawal, however the University was unable to support the withdrawal date. Per the University’s calculation, 100% of the aid was earned and no R2T4 was processed, however without support for the official date of withdrawal or last date of attendance, the University should have used the 50% default and processed as an unofficial withdrawal. This would have resulted in return of funds. Another official withdrawal student tested was processed with a withdrawal date that resulted in the student having attended more than 60% of the term, and therefore earning 100% of aid disbursed. However, the University was unable to support the date used. Per documentation provided, it appears the student initiated the official withdrawal process on an earlier date. Had this date been used, a return would have been due. Our sample was not, and was not intended to be, statistically valid. Questioned costs – Undeterminable. Cause/effect – This occurred because of lack of controls and processes in place to ensure supporting documentation is maintained for student’s withdrawal dates. This resulted in the calculations being incorrect and money not being returned to the federal government. Repeat finding – No Recommendation – We recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Views of responsible officials and planned corrective actions – In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031S170020, P031C210038 Award Year: 2022-23, 2021-22 Federal Assistance Listing Number: 84.425E, 84.425F Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion, Federal Award Number: P425F201298 Award Year: 2022-23 Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases. Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur. Repeat finding – Yes, 2022-006 Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts. Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Department of Education Student Financial Assistance Cluster Federal Assistance Listing Number: 84.038 Federal Program Name: Federal Perkins Loan Program Award Year: 2022-23 Criteria – In accordance with 34 CFR 674.19(d) the institutional must maintain program and fiscal records of all Perkins funds since the most recent Fiscal Operations Report (FISAP) was submitted and reconcile this information at least monthly. Condition/context – The University could not provide the required reconciliations as required by 34 CFR section 674.19(d). Our sample was not, and was not intended to be, statistically valid. Questioned costs – None. Cause/effect – This occurred because of a lack of understanding of the compliance requirements for Perkins program and fiscal records. The University is unable to provide support that the program and fiscal records of all the Perkins funds reconciles to the most recent FISAP. Repeat finding – No Recommendation – We recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans was properly liquidated. Views of responsible officials and planned corrective actions – To ensure the Perkins loan portfolio was correctly liquidated, the University will reconcile the data with the most current FISAP filed.