Audit 290586

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, the University did not designate a qualified individual responsible for overseeing and implementing the information and security program. Context: These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Questioned costs: None. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat Finding: No Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 682.604, states that a school must ensure that exit counseling is conducted with each Stafford Loan borrower and graduate or professional student PLUS Loan borrower either in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that this counseling is conducted shortly before the student borrower ceases at least half-time study at the school. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 4 students that did not have documentation of exit counseling notification. Questioned costs: None. Cause: The University did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Effect: Exit counseling helps federal student loan borrowers understand how to repay their loans and reviews deferment and repayment plans options. If students are not notified of exit counseling, they could be at risk of not understanding their rights and responsibilities regarding loan repayment. Repeat Finding: No Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 17 students had the incorrect effective date for campus-level and program-level enrollment, 1 student had the incorrect effective date for only program-level enrollment, 10 students were reported past the 60-day reporting timeframe, and 4 students did not have their graduate status reported to NSLDS. Questioned costs: None. Cause: The University did not have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: No. Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly awarded Pell Title IV Funds. Context: During our testing we identified 2 out of 40 students were awarded incorrect Pell amounts based on the 2022-23 Pell payment schedule. Of the two instances, one student was under awarded $861 of Pell, while the other student was over awarded $564. The Pell payment schedule takes into account the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None. Cause: The University did not award the correct amounts of the Pell. Effect: Students were not awarded proper amount of Pell they were eligible for. Repeat Finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal agency: Department of Education Federal program title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: P007A223438 - 2023, P033A223438 - 2023, P063P222047 - 2023, P268K232047 - 2023 Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University incorrectly calculated and did not disburse aid timely for Return to Title IV (R2T4) calculations. The University also did not have formal procedures in place to review the Return to Title IV calculations. Context: During our testing of 14 R2T4s, we identified that 9 R2T4 calculations had mechanically incorrect calculations. Out of the 9, 7 had the incorrect number of scheduled break days, and 6 had incorrect disbursed amounts. Also, during our testing, we identified 1 instance of payments returned later than 45 days after withdrawal. Additionally, we were unable to identify formal control procedures related to Return to Title IV transactions. Questioned costs: $3,391 Cause: The University was incorrectly calculating R2T4s as well as using the incorrect number of scheduled break days for Spring Semester. Additionally, the University did not have a formal procedure for reviewing R2T4s. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.