Audit 292382

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-01 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that attributed to this finding: 1) Of the 60 students tested, there were 2 students who withdrew whose status changes were not reported accurately to the NSLDS. The students withdrew and were reported but with incorrect effective dates. 2) Of the 60 students tested, there were 13 students who withdrew or graduated whose status changes were not reported to the NSLDS within 60 days. 3) Of the 60 students tested, there were 3 students who withdrew whose status changes were not reported to the NSLDS. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Additional staff training will be completed by the new Assistant Registrar and other staff within Records & Registration. Some duties will be shifted between staff better manage project time commitments and ensure accuracy. As of August 3, 2023, fall 2022 and spring 2023 identified students have been corrected in NSC and/or NSLDS. The monthly process to review all withdrawals that was implemented following the 2021 - 2022 audit will continue with additional controls to ensure each required step has been signed off on with additional review for compliance by the Director of Student Account Services and the Registrar. Implemented improvements to monthly Student Account Services and University Billing (SASUB) and Registrar’s Office enrollment reporting communication workflow to track completion and ensure timely reporting for the fall 2023 semester, including the following: • Date last date of attendance is determined • Date file is sent to Registrar’s Office • Date Registrar’s Office reviews each student on list • Date Registrar’s Office updates NSC and/or NSLDS • Date final compliance review against mandated reporting timelines is completed Registrar’s Office and Office of Scholarships & Financial Aid, in collaboration with academic leadership, initiated a verification of non participation process in summer 2023. Faculty will provide notification of any student who does not complete at least one academic related activity within the first two weeks of any course. The process was fully implemented for the fall 2023 semester. Additionally, the University is implementing a new financial aid system for the 2024 - 2025 aid year. Functionality in the new software will be utilized to assist with timely enrollment reporting.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-02 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University has discrepancies between the date utilized in the return to Title IV calculations and the date required to be utilized based on federal regulations. Questioned Costs - $5,048 Identification of How Questioned Costs Were Computed - Recalculation of returns was based on correct withdrawal and semester begin/end dates. Context - There were three errors attributed to this finding: 1) Of the 60 students tested, there were 2 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on federal regulations. 2) Of the 60 students tested, there was 1 identified for whom no return to Title IV calculation was performed, and, therefore, there was no return of funds until the student was selected for testing for the audit. 3) Of the 60 students tested, there was 1 identified for whom the incorrect amount of aid was returned. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated accurately. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated accurately. Views of Responsible Officials and Planned Corrective Actions - To address the first and third errors, the following actions will be taken: • To reinforce procedural knowledge of the return of Title IV aid, the staff responsible for the calculation of return of Title IV funds will complete a training course provided by the National Association of Student Financial Aid Administrators titled Return of Title IV Funds FA23. • Each semester, return procedures will be reviewed by staff and training on the use of the review checklist will be completed. • The Director of Student Account Services will perform audits of calculations each semester. • It will be requested that the Internal Audit department assist in the same. To address the second error, the Financial Aid Office will complete a monthly reconciliation to ensure the students receiving aid are enrolled by comparing enrollment reports from the student information system (SIS) and financial aid system. Additionally, the University is implementing a new financial aid system and will ensure integration between the SIS and financial aid system are working properly.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - An institution may enter into an arrangement with a servicer or a financial institution to make a direct payment of FSA credit balances to students through electronic funds transfer to a bank account designated by a student or parent; to issue a check payment to the student; or to use an access device such as a debit, demand, or smart card provided by the servicer or its financial partner. Regulations at 34 CFR 668.164(e) and (f) establish two different types of arrangements between schools and financial account providers: Tier One arrangements and Tier Two arrangements. The type of arrangement determines the provisions that are applicable to the school. A Tier One arrangement is an arrangement between a school and a third party servicer under which the servicer performs one or more of the functions associated with processing direct payments of Title IV funds on behalf of the school, and the school or third party servicer makes payments to one of the following: one or more financial accounts that are offered to students under the contract; a financial account where information about the account is communicated directly to students by the third party servicer, or the school on behalf of or in conjunction with the third party servicer; or a financial account where information about the account is communicated directly to students by an entity contracted or affiliated with the third party servicer (34 CFR 668.164(e)(1)). A Tier Two arrangement is an arrangement between a school and a financial institution, or an entity that offers financial accounts through a financial institution, under which financial accounts are offered and marketed directly to students (34 CFR 668.164(f)(1)). ED considers that a financial account is marketed directly if (a) the school communicates information directly to its students about the financial account and how it may be opened; (b) the financial account or access device is cobranded with the school's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or (c) a card or tool that is provided to the student for school purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account (34 CFR 668.164(f)(3)). Schools are required to disclose the arrangement on their website, as well as other disclosure requirements outlined in 34 CFR 668.164. Condition - The University was not compliant in disclosure requirements surrounding Tier One and Tier Two arrangements. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified attributed to this finding: 1) The University did not disclose on its website the contract between the school and its Tier Two provider. 2) The University did not provide a URL for the contracts or cost information of its Tier One or Tier Two providers to ED for publication in the Cash Management Contracts Database. 3) The University did not perform a due diligence review of its Tier Two provider to ascertain whether the fees imposed under the arrangement are consistent with or below prevailing market rates. Cause and Effect - The University did not have a control in place to ensure all aspects of Tier One and Tier Two arrangements were compliant with requirements. Recommendation - The University should implement controls to ensure Tier One and Tier Two arrangements are compliant with requirements. Views of Responsible Officials and Planned Corrective Actions - The errors have been corrected, and the University has a clearer understanding of the expectations related to cash management. Going forward, two individuals (the Director of Student Account Services and the Student Accounts website contact) will utilize calendar reminders to ensure compliance with the noted findings, as well as all required cash management compliance issues.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass through Entity - None Finding Type - Significant deficiency Repeat Finding - No Criteria - Per Part 5 of the Compliance Supplement, "a student must maintain good standing, or satisfactory academic progress." Additionally, per 34 CFR 668.32(f), a student is eligible to receive TIV aid if meeting all requirements as well as "maintains satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of § 668.34." One aspect an SAP policy must include per 34 CFR 668.34 5ii, "For a credit hour program using standard or nonstandard terms that is not a subscription based program, the pace, measured at each evaluation, at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe, calculated by either dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted or by determining the number of hours that the student should have completed by the evaluation point in order to complete the program within the maximum timeframe. In making this calculation, the institution is not required to include remedial courses." Condition - The University is not following its Satisfactory Academic Progress (SAP) policy for all students. Questioned Costs - $13,296 Identification of How Questioned Costs Were Computed - Total of aid disbursed for semester SAP policy was not followed. Context - Of the 25 students tested, there was one student who had fallen below the threshold of 67 percent completion rate per the University's Satisfactory Academic Progress policy at the time academic progress would be measured and the SAP policy was not followed to address student progress. Cause and Effect - The University did not have a control in place to ensure students were in compliance with the University's policy. Recommendation - The University should implement controls to ensure students are compliant with policy. Views of Responsible Officials and Planned Corrective Actions - A policy update to the quantitative component of satisfactory academic progress was implemented to measure SAP based on cumulative data. The full policy, informational website, student communications, and financial aid system were all updated. This policy update is effective for the 2023-2024 academic year with the first official evaluation point assessing cumulative data at the end of fall 2023.