Audit 290552

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.263 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.263 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Gramm-Leach-Bliley Act (GLBA) Compliance Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.268, 84.063, 84.007, and 84.033-Student Financial Assistance Cluster Federal Award Identification #: 2022-2023 Financial Aid Year Condition: The University did not sufficiently comply with all the requirements of GLBA. Criteria: 16 CFR 314.3, 16 CFR 314.4 Questioned Costs: $0 Context: The University has not documented each component of GLBA as required. This includes documenting an information security program, documenting the security risk assessment and safeguards, including general threats, implementing multi-factor authentication on all systems containing personally identifiable information (PII), implementing continuous monitoring, such as penetration testing and vulnerability scanning, implementing sufficient vendor management policies and reviews, and providing a written, annual report to the board covering all required areas. Cause: The University has not allocated sufficient resources to address and document compliance with the requirements of GLBA. Effect: The University has not adequately addressed the requirements of GLBA, which may lead to unintended exposure of student information to security risks. Identification as repeat finding, if applicable: Not applicable Recommendation: We recommend the University allocate sufficient resources to address all requirements of GLBA. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Material Weakness DEPARTMENT OF EDUCATION ALN #: 84.063, 84.263 and 84.007 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: When students withdrew either officially or unofficially, the University did not always return unearned Title IV aid accurately or timely. Criteria: 34 CFR 668.22 and 34 CFR 690.63 Questioned Costs: $11,226 Context: Out of 25 students tested, three modular students who did not meet the exemption rules for modular students, resulted in late returns and incorrect Pell recalculations. Pell should have been recalculated for failure to begin attendance in all classes awarded and those funds returned prior to completing the R2T4. This resulted in under returns totaling $3,709 of Pell, $300 of FSEOG and $1,831 of Federal Direct loans (FDL). The exceptions were corrected during the audit in November 2023. Two students in a distance education modular program did not have documented academic engagement to establish attendance in each module, therefore not meeting an exemption and should have an R2T4 completed. This resulted in a late return of $1,159 for Pell and $2,001 for FDL. These exceptions were corrected during the audit in November 2023. A return was never made for another traditional student who did not participate past 60% of the semester resulting in a late return of $837 for Pell. This exception was corrected during the audit in November 2023. One modular student had the incorrect amount returned due to an incorrect R2T4 calculation resulting in an under-return of $1,374 of Pell and $15 of FDL. This exception was corrected during the audit in November 2023. Two other students had the correct amount returned however they were returned after the 45 day return window. The returns totaling $7,589 were late between 154-199 days. Cause: This was an oversight by the University. Students in modular programs who withdrew either officially or unofficially did not meet an exemption but no R2T4 was completed. Pell was not recalculated for classes that students did not begin attendance in. Effect: Noncompliance with new R2T4 regulations regarding withdrawals from modular programs, return of Title IV funds were not performed timely and incorrect amounts of federal funding were returned. Identification as repeat finding, if applicable: 2022-004 Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review standard and modular students R2T4 calculations and returns to help ensure that internal controls over such processes can operate effectively and achieve compliance. As part of this process, we also recommend reviewing students with Title IV aid that have no passing grades in a module or term for potential unofficial withdraws and document determination as to whether or not an R2T4 is required. We further recommend the University adjust procedures to identify whether any Pell recalculations are required to be completed first before the R2T4 calculation is completed. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.263 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.

DEPARTMENT OF EDUCATION ALN #: 84.063 and 84.263 Federal Award Identification #: 2022-2023 Financial Aid Year Condition: Detailed reconciliations between COD and the University student information system were not performed. Criteria: 34CFR 668.164(a) Questioned Costs: $0 Context: Of the three months of reconciliations that were tested, it was noted that the reconciliations between COD and the University student information system were performed on a batch basis and were not on a student-by-student basis. Cause: Oversight by the University. The reconciliations of University records to COD were not completed on a student-by-student basis. Effect: Potential differences between the system and COD resulting in inaccurate student Title IV records. Identification as repeat finding, if applicable: 2022-006 Recommendation: We recommend that the University implement procedures to monthly reconcile FDL and Pell disbursements to individual student accounts with disbursements reported to COD. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See corrective action plan.