Audit 293212

ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268 (Questioned Costs - None) (Repeat) Condition: When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis, the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days. During our audit, we noted 8 (eight) instances in which student status changes were reported more than sixty (60) days after the occurrence. Context: A haphazard selection of ten (10) students was made from the list of student withdrawals and graduates during the year. Criteria: Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated, enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309] Effect: The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a requirement for Federal Direct Loan (FDL) eligibility. Cause: Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the enrollment status of students. Recommendation: The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness of student status filings will aid in the transition of students to loan repayment status. Views of Responsible Officials and Planned Corrective Actions: The University submitted a corrective action plan that was acceptable by DOE. and implemented effective 9/1/2022.

PROCEDURES USED TO IDENTIFY STUDENTS FOR THE RETURN OF TITLE IV FUNDS SHOULD BE IMPROVED STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268 (Questioned Costs-Undetermined) (Repeat) Condition: When a recipient of Title IV grant or loan assistance withdraws from an institution of higher learning 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 the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in the regulations. During our audit we noted that the University’s did not perform the R2T4 calculations in a timely manner as required by the Department of Education regulations. Context: Review of internal controls and related procedures in place for identifying students ceasing to attend or enroll and the procedures in place to identify when a student withdraws or fail to properly enroll. Policies in place to determine the timeliness of calculating the required return of federal funds as prescribed by the Department of Education. Criteria: Controls should be in place to ensure that when a student ceases to attend the University the proper procedures are followed. The financial aid personnel and the accounting department and the management accounting systems of each non-Federal entity must provide for, effective controls over, and accountability for all students the withdraws from the University [2 CFR §668.22]. Effect: Management may not be able to obtain complete and accurate information to determine when a student withdraws from the University and therefore, not properly calculate the R2T4 funds. Cause: Turnover in the student financial aid department and weaknesses in processes related to procedures determining official withdrawals, un-official withdrawals and students failing to return for the next semester. Recommendation: The policies and procedures in place to identify students withdrawing from the University should be reviewed and improved to ensure that when a student ceases to enroll or withdraws from the institution (officially or un-officially) the proper procedures are followed, as outlined in the federal regulations. Timely R2T4 calculations should be performed and appropriate grant or loan funds should be timely remitted back to the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

ENROLLMENT REPORTING PROCEDURES SHOULD BE STRENGTHENED STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268 (Questioned Costs - None) (Repeat) Condition: When the Registrar’s Office discovers that a student did not enroll or ceased to be enrolled on at least a half-time basis, the National Student Loan Data System (NSLDS) should be notified of the change in the student’s enrollment status within thirty days of the occurrence, unless the Institution expects to complete its next scheduled filing within sixty days. During our audit, we noted 8 (eight) instances in which student status changes were reported more than sixty (60) days after the occurrence. Context: A haphazard selection of ten (10) students was made from the list of student withdrawals and graduates during the year. Criteria: Federal regulations require the Institution to notify the NSLDS of a change in student status (i.e., withdrawn, graduated, enrolled less than half-time, etc.). Unless the Institution expects to complete its next filing within sixty days, the Institution must notify the NSLDS within thirty days if it discovers a student with an outstanding federal loan balance has ceased to be enrolled on at least a half-time basis. [34 CFR 685.309] Effect: The lender or guaranty agency is not receiving prompt notification of changes in borrower’s enrollment status. This results in delayed processing of loan repayment periods and leads to poor default management. Late or incorrect updates to the NSLDS may also cause students to receive loans for which they are not eligible, as half-time enrollment is a requirement for Federal Direct Loan (FDL) eligibility. Cause: Necessary withdrawal documentation is not consistently processed and forwarded to appropriate departments in a timely manner to ensure reports are accurately filed as scheduled. Overall, there is an inadequate process of verifying the enrollment status of students. Recommendation: The Institution should implement procedures to ensure compliance with federal regulations. The Registrar’s Office should obtain a complete understanding of the NSLDS reporting requirements. Improving the accuracy and timeliness of student status filings will aid in the transition of students to loan repayment status. Views of Responsible Officials and Planned Corrective Actions: The University submitted a corrective action plan that was acceptable by DOE. and implemented effective 9/1/2022.

PROCEDURES USED TO IDENTIFY STUDENTS FOR THE RETURN OF TITLE IV FUNDS SHOULD BE IMPROVED STUDENT FINANCIAL AID CLUSTER PROGRAM CFDA # 84.268 (Questioned Costs-Undetermined) (Repeat) Condition: When a recipient of Title IV grant or loan assistance withdraws from an institution of higher learning 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 the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs as outlined in the regulations. During our audit we noted that the University’s did not perform the R2T4 calculations in a timely manner as required by the Department of Education regulations. Context: Review of internal controls and related procedures in place for identifying students ceasing to attend or enroll and the procedures in place to identify when a student withdraws or fail to properly enroll. Policies in place to determine the timeliness of calculating the required return of federal funds as prescribed by the Department of Education. Criteria: Controls should be in place to ensure that when a student ceases to attend the University the proper procedures are followed. The financial aid personnel and the accounting department and the management accounting systems of each non-Federal entity must provide for, effective controls over, and accountability for all students the withdraws from the University [2 CFR §668.22]. Effect: Management may not be able to obtain complete and accurate information to determine when a student withdraws from the University and therefore, not properly calculate the R2T4 funds. Cause: Turnover in the student financial aid department and weaknesses in processes related to procedures determining official withdrawals, un-official withdrawals and students failing to return for the next semester. Recommendation: The policies and procedures in place to identify students withdrawing from the University should be reviewed and improved to ensure that when a student ceases to enroll or withdraws from the institution (officially or un-officially) the proper procedures are followed, as outlined in the federal regulations. Timely R2T4 calculations should be performed and appropriate grant or loan funds should be timely remitted back to the Department of Education. Views of Responsible Officials and Planned Corrective Actions: The University has implemented policy and procedures that require a review of all official and unofficial withdrawals to have R2T4 calculations on a real time basis to ensure compliance with the Department of Education guidelines on a consistent and regular basis. Internal audits of the process will also be implemented for continuous improvement.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

INTERNAL CONTROL AND COMPLIANCE WITH THE HIGHER EDUCATION EMERGENCY RELIEF FUND AND PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND CFDA # 84.425E, 84.425F, 84.425L AND 84.425N (Questioned Costs-Undetermined) (Repeat) Condition: During the year 2021, the University was awarded Coronavirus Aid, Relief, and Economic Security Act (CARES Act) of approximately $978,035 under the Higher Education Emergency Relief Fund Student Aid Portion, the Higher Education Emergency Relief Fund Institutional Portion and the Higher Education Emergency Relief Fund Minority Serving Institutions. Collectively, the HEERF awards (or program) which was a major federal program for the year ended June 30, 2021. The internal controls over the compliance and administration of the new program requires management of the University to comply with all direct and material compliance requirements outlined in the federal Compliance Supplement Addendum for 2021 for the HEERF program. While the University established a plan to distribute funds students in accordance with the CARES Act and to cover qualified expenditures for the Institution portion, it fail to properly maintain detailed records of the actual distributions to each student so that a reconciliation of the distributed funds could be reconciled to the subsidiary accounts in the general ledger. In addition the University fail to properly maintain its documentation of the loss revenue calculation as require by the CARES Act or the Institution’s portion. The University also fail to provide complete evidence of the quarterly and annual reporting as required by the Section 18004(a)(1) and 18004 ( c) of the CARES Act. Context: Review of the University’s controls and compliance requirements for activities allowed and unallowable and allowable costs/cost principles and the reporting requirements for quarterly reporting for the quarters ending September 30, 2021 December 31, 2021 and March 31, 2022 and June 30, 2022. We selected all students Martin University determined to be eligible for the HEERF student portion disbursement and only 51 were verified as actually receiving the disbursement. Criteria: The University must comply with the CARES Act Sections 18004(a)(1) Institutional Portion, (a)(2) and (a)(3) Quarterly Public Reporting for all applicable CFDAs under 84.425E, 84.425F, 84.425L and 84.425N. Effect: The University may not be able to adequately document its compliance with the requirements of the CARES Act for the HEERF program administered. Cause: The University did not established a system of internal control over compliance due to timing of the award and the impact the pandemic had on the training of management and staff. A complete understanding of the HEERF program requirements were not completely understood to properly complete the system of internal control and compliance documentation in a timely manner and in all material respects. Recommendation: The University must complete its internal control and compliance policies and procedures over the HEERF program and complete the accounting and reconciliation requirements as set forth by federal regulations of the HEERF program. Specifically, activities allowed and unallowable and allowable costs/costs principles. In addition to completing the quarterly reports as required by federal regulations. If the Department of Education has established the annual reporting portal, the University should also complete that reporting requirement in connection with the reconciliations of the annual report with the quarterly reports for 2020 and 2021. Views of Responsible Officials and Planned Corrective Actions: The University has implemented a policy that requires a complete review of the internal controls over the compliance of the HEERF programs and to make sure that all required areas of compliance supplement are achieved. The updated policy was provided to the Grants Risk Management Services Division of DOE on 12/14/2023.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

Comment 2021-006 THE UNIVERSITY FAILED TO COMPLETE AND FILE ITS ANNUAL AUDIT AND COMPLETE ITS FILING WITH THE FEDERAL AUDIT CLEARING HOUSE FOR THE JUNE 30, 2021 YEAR END STUDENT FINANCIAL AID CLUSTER AND OTHER FEDERAL PROGRAMS CFDA # 84.007, 84.033, 84.063, 84.268, 84.425E, 84.425F, 84.425L, 84.425N and 84.287 (Questioned Costs - None) (Repeat) Condition: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. Section 200.512 states that the audit must be completed and the data collection form filed with the Federal Audit Clearing House within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Certain extensions were granted due to the pandemic. The University is also required to submit its audit to the Department of Education FSA eZ-Audit System. The University failed to complete and submit its June 30, 2021 audit in a timely manner as required by federal regulations. Context: Review of the University’s reporting requirements under the Uniform Guidance and the Department of Education eZ- Audit System requirement. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements for Federal Awards (Uniform Guidance), Section 200.508 - Auditee responsibilities, requires the auditee (the University) arrange for the audit of the its financial statements to meet the requirements as set forth in Section 200.512, Report submission. FSA eZ-Audit System. Effect: The University is subject to general and specific sanctions as set forth in federal regulations. Cause: The University did not perform its independent due diligence with respect to the federal reporting requirements and filing its annual audit report as set forth by the Uniform Guidance. The University’s board of trustees and senior management relied entirely on the former CFO to fulfill the regulatory filing requirements. Recommendation: The University must established, through its board of Trustees, an independent committee thoroughly familiar with the federal and state reporting requirements promulgated by the Uniform Guidance, the Department of Education and the State of Indiana to ensure complete compliance with the various reporting mandates set forth by regulators. Views of Responsible Officials and Planned Corrective Actions: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual traning on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President's Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY 2021 audit in December 2023. The Universith received an extension from the DOE to complete its FY 2022 audit by March 2024.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.

CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND RECONCILIATION PROCEDURES SHOULD BE IMPROVED HIGHER EDUCATION EMERGENCY RELIEF FUND STUDENT FINANCIAL AID CLUSTER PROGRAM (Questioned Costs-Undetermined) Condition: Management is responsible for the preparation and fair presentation of its financial statements in accordance with generally accepted accounting principles (GAAP) and the schedule of expenditures of federal awards (SEFA). However, we provided assistance to management in the preparation of the financial statements, SEFA, and related disclosures of the University. Effective for the year ended June 30, 2019, the University was charged with the responsibility of implementing FASB ASU No. 2016-14 - Presentation of Financial Statements of Not-For-Profit Entities. The objective of the FASB is to improve the current net asset classification requirements and the information presented in financial statements and notes about a not-for-profit entity’s liquidity, financial performance, and cash flows . FASB ASU No. 2018-08 , Not-for-Profit Entities (Topic 958): Clarifying the Scope and Accounting Guidance for Contributions Received and Contributions Made and FASB ASU 2016-18 (Topic 230) Statement of Cash Flows, were also required to be implemented beginning 2019. While management demonstrated efforts to comply with the new standards and in its accounting processes, there was still a need for significant adjustments proposed and enhanced disclosures during the audit process to properly state various assets, liabilities, revenue and expense accounts and to the related disclosures. We also noted that there were significant weaknesses in the internal control over reconciliation procedures in the area of student accounts receivables, posting of various transactions to student accounts, bad debt, financial aid, recording HEERF funds and disbursing HEERF funds (student portion) to eligible students. The general ledger and subsidiary accounts were not reconciled between systems (CAM vs Microsoft Dynamics vs EDExpress) During the year, the University received new funding from the Coronavirus Aid Relief and Economic Security Act (CARES Act) authorized under the Higher Education and Emergency Relief Fund. We noticed that funding drawn under these grants could not be traced in their entirety to cost centers where disbursements were made for relevant expenditures. The HEERF annual reporting requirement was not complete and accurately reported nor available during the audit. Context: Review of the internal controls related to financial statement preparation in accordance with Government Auditing Standards. Criteria: Controls should be in place to ensure that financial statements are prepared in accordance with GAAP. The auditee must prepare financial statements that reflects its financial positions, results of operations or changes in net assets, and where appropriate, cash flows for the fiscal year ended. [2 CFR §200.510(a)]. The financial management system of each non-Federal entity must provide for, comparison of expenditures with budget amounts for each Federal award. [2 CFR §200.302(b)(5)]. Effect: Management may not be able to obtain complete and accurate financial statements on an interim or fiscal year basis to be used for internal or external reporting purposes on a timely basis. Lack of effective budgeting can lead to budget overruns or inefficient use of grant funds. Cause: Continual change in accounting function in recent years and turn-over in various departments Recommendation: The degree to which assistance in the preparation of the financial statements and the related disclosures by independent auditor is a control deficiency is determined by the knowledge and expertise of those in the University who are charged with the responsibility of financial reporting. As a result, it is our recommendation that key personnel that have a role in the financial reporting process continue to review the functionality of their financial accounting system to see if grant reporting capabilities can be enhanced. We also recommend that the accounting department and the financial aid department enhance its procedures to improve communications and reconciliation procedures in order to complete the required reconciliation procedure when federal funds are drawn and recorded in the various accounting modules. Views of Responsible Officials and Planned Corrective Actions: The University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University has begun to restructure all accounting and reconciliation functions, including implementation of new accounting software. The University is implementing financial internal controls to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards.