Audit 291731

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program Federal Financial Assistance Listing #84.033 Work‐Study Program ‐ 2022/2023 P063P201430 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University’s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1‐23, columns e and f. Cause: The University recorded the first line noted above as the cumulative total instead of only the amount that related to the year ended May 31, 2022. The federal work‐study numbers included other student workers paid with nonfederal funds. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program Federal Financial Assistance Listing #84.033 Work‐Study Program ‐ 2022/2023 P063P201430 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University’s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1‐23, columns e and f. Cause: The University recorded the first line noted above as the cumulative total instead of only the amount that related to the year ended May 31, 2022. The federal work‐study numbers included other student workers paid with nonfederal funds. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

COVID‐19 Higher Education Emergency Relief Funds – Institution Share – Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that they entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The University’s lost revenue calculation should be calculated on a reasonable and consistent method. Condition: The University’s calculated lost revenue was based on the average credit hours per semester prior to COVID‐19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID‐19 resulting in an understated amount of lost revenue from the intended methodology. Cause: The University’s internal control process did not detect that the lost revenue based on credit hours was improperly calculated. Effect: The lost revenue calculation was understated by approximately $750,000. Questioned Costs: None as the University’s lost revenue available only would have increased. Context/Sampling: Lost revenue for all applicable years and revenue streams were tested and reviewed. Repeat Finding from Prior Years: No Recommendation: The University should review controls in place to ensure lost revenue is calculated consistently. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program Federal Financial Assistance Listing #84.033 Work‐Study Program ‐ 2022/2023 P063P201430 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University’s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1‐23, columns e and f. Cause: The University recorded the first line noted above as the cumulative total instead of only the amount that related to the year ended May 31, 2022. The federal work‐study numbers included other student workers paid with nonfederal funds. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.038 Federal Perkins Loan Program Federal Financial Assistance Listing #84.033 Work‐Study Program ‐ 2022/2023 P063P201430 Reporting Significant Deficiency in Internal Control over Compliance Criteria: 34 CFR 673.3 requires institutions complete the Fiscal Operations Report and Application to Participate (FISAP) to participate in the Federal Perkins Loan Program. The Fiscal Operations Report includes the University’s financial information from the previous award year. Condition: Certain amounts within the FISAP filed during fiscal year 2022 FISAP were reported incorrectly in Part III, Section B, Line 13 and in Part VI, Section A, Lines 1‐23, columns e and f. Cause: The University recorded the first line noted above as the cumulative total instead of only the amount that related to the year ended May 31, 2022. The federal work‐study numbers included other student workers paid with nonfederal funds. Effect: Information reported on the FISAP was incorrect. Questioned Costs: None Context/Sampling: Key line items within the FISAP report were tested as required by the OMB Compliance Supplement. No statistical sampling was performed. Repeat Finding from Prior Years: Yes Recommendation: The University should review current processes to ensure that line items reported are accurate. The FISAP review process should include a detail review by an individual independent from the preparer to verify the numbers reported. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Return of Title IV Funds Material Weakness in Internal Control over Compliance Criteria: The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Condition: Eight instances were identified where there was no documented control over the Return of Title IV calculation. Cause: The University did not have a documented control over all of the Return of Title IV calculations. Effect: Without a secondary review and approval, there is a possibility that the Return of Title IV calculations could be incorrect. Questioned Costs: None Context/Sampling: Of the 16 students in which a Return of Title IV funds were calculated, 3 were tested. There were also 9 additional students that were tested based on a population of all withdrawn students or 46 students. The amount tested was $60,000 of the total population of funds received of $299,000. Repeat Finding from Prior Years: Yes Recommendation: The University should review its current controls over Return of Title IV calculations and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Criteria: The University is required to verify information in student aid applications selected by the Department of Education and the verified applications were in compliance with the verification requirements. Condition: Four instances were identified where there was no documented control over student verification. Cause: The University did not have a documented control over all of student verification. Effect: Without a secondary review and approval, there is a possibility that data corrections as a result of student verification could be incorrect. Questioned Costs: None Context/Sampling: Of the 22 students in which required student verification, 4 were tested. Repeat Finding from Prior Years: No Recommendation: The University should review its current controls over student verification and ensure those controls are properly documented. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans ‐ 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program ‐ 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Criteria: A student’s enrollment status determines eligibility for in‐school status, deferment, and grace periods, as well as for the payment of interest subsidies to federal direct loan program loan holds by Education Department. Reporting in a timely and accurate manner is critical for effective management of the programs. An institution must submit student status changes to the National Student Clearing House, no later than 60 days after the Institution’s Determination Date. In addition, the enrollment effective date reported to the National Student Clearing House should be the same as the student’s last date of attendance for withdrawals. Condition: One instance was noted where enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Cause: The University did not include the intersession course its calculation of enrollment status for the Spring semester to be submitted to National Student Clearing House. Effect: The enrollment status reported to the National Student Clearing House was not reflective of the student’s actual enrollment status. Questioned Costs: None Context/Sampling: Non‐statistical sampling was performed. One instance was identified in 60 students tested. 374 students had status changes during the year. Repeat Finding from Prior Years: Yes Recommendation: The University should implement controls to ensure student status changes are correctly processed in the National Student Clearing House. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.

COVID‐19 Higher Education Emergency Relief Funds – Institution Share – Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that they entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The University’s lost revenue calculation should be calculated on a reasonable and consistent method. Condition: The University’s calculated lost revenue was based on the average credit hours per semester prior to COVID‐19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID‐19 resulting in an understated amount of lost revenue from the intended methodology. Cause: The University’s internal control process did not detect that the lost revenue based on credit hours was improperly calculated. Effect: The lost revenue calculation was understated by approximately $750,000. Questioned Costs: None as the University’s lost revenue available only would have increased. Context/Sampling: Lost revenue for all applicable years and revenue streams were tested and reviewed. Repeat Finding from Prior Years: No Recommendation: The University should review controls in place to ensure lost revenue is calculated consistently. Views of Responsible Officials: Management agrees. Management’s complete response can be found in the separately issued corrective action plan.