Audit 290967

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-002 Common Origination and Disbursement (COD) Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the University to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing of 40 disbursements, we noted one Pell disbursement date per COD did not align with the student account disbursement date. Questioned costs: None Context: During our testing, it was noted the University did not properly follow the process to ensure disbursements are accurately reported to COD. Cause: The University did not follow the procedure to meet the requirement that disbursements made to students must be reported to COD within 15 days of the disbursement date. Effect: Students interest accrues based on disbursement date reported to COD for Pell disbursements, thus interest calculation could be skewed due to the discrepancy in disbursement dates reported. Repeat Finding: No Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-003 National Student Loan Data System (NSLDS) Enrollment Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Condition: During our testing, we noted 16 out of the 40 students tested where the student was not reported in a timely manner after the school determined the students change in status. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to ensure timeliness of NSLDS reporting. Cause: The University did not have a process in place to ensure the student who graduated or withdrew were reported timely. Effect: The University did not comply with Department of Education (ED) regulations by reporting student enrollment status changes timely. Repeat Finding: Yes - 2022-001 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Views of Responsible Officials: There is no disagreement with the audit finding

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-004 Eligibility Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: Per the Code of Federal Regulations, 34 CFR 673.5, students may not be awarded need based aid in excess of their calculated need. In addition, 34 CFR 685.203(j) states that in no case may a loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loan is intended less the student’s estimated financial assistance for that period and in the case of Direct Subsidized Loans, the borrower’s expected family contribution for that period. Condition: During our testing, we noted for 2 out of 40 students tested, we noted an over award. For one of these students, it was an over award of need-based aid in the amount of $672 as total aid paid was greater than the student's total need in the 2022-23 academic year. For the other student, we noted an over award of $1,467 of overall aid during the 2022-23 academic year that was greater than the student’s cost of attendance. Questioned Costs: $2,139 Context: During our testing, it was noted an erroneous computation of the student’s financial need and cost of attendance thus causing an over award in need based and overall aid. Cause: Management incorrectly awarded these students based on their financial need and cost of attendance. Effect: The University is not in compliance with Department of Education requirements. Repeat Finding: Yes – 2022-002 Recommendation: We recommend the University implements policies to review all student award packages at the start of the academic year to ensure no over awards exist. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-005 Special Test: 240 Day Checks Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h)(2) states that an institution that attempts to disburse funds by check and the check is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued that check. Condition: Twenty checks totaling $12,138.00 related to student refunds of Title IV federal financial aid were outstanding more than 240 days as of June 30, 2023. Questioned Costs: $12,138 Context: During our testing, it was noted the University does not have a process in place to ensure checks are refunded to ED after 240 days outstanding. Cause: The University did not have a process in place to ensure all outstanding checks over 240 days was properly returned to the ED. Effect: The University is not in compliance with Department of Education requirements that all student refund checks that are outstanding for more than 240 days be returned to the Department. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023-006 Eligibility – First Time Borrower Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Criteria or Specific Requirement: An institution may not make a disbursement of a Direct Loan to a first-year undergraduate who is a first-time borrower until 30 days after the first day of classes of the payment period (34 CFR 668.164(i)(2)(i) and 34 CFR 685.303(b)(5)) Condition: During our testing, we noted 2 out of the 40 students were first time borrowers who received a disbursement of Direct Loans within 30 days after the first day of classes. The University was required to wait until after 30 days of the first day of classes. For both cases, the student remained enrolled, so there was no need to issue a refund. Questioned Costs: None Context: During our testing, it was noted the University does not have a process in place to comply with the federal regulations. Cause: The University did not have a process in place to ensure compliance with federal regulations. Effect: The University is not in compliance with Department of Education requirements in regards to first-time borrowers receiving Direct Loans. Repeat Finding: No Recommendation: We recommend that the University review its procedures related to first-time borrowers to ensure they are in compliance with the Department of Education's regulations. Views of Responsible Officials: There is no disagreement with the audit finding.