Audit 295211

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-004 Criteria - Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program and how and when those funds will be disbursed. If those funds include Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Federal Direct Loans, the institution must notify the student or parent of the following: (i) The anticipated date and amount of the disbursement (ii) The student's or parent's right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the secretary (iii) The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement Condition - The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 50 students tested for eligibility with Federal Direct Loans, the disbursement notification sent to the student and/or parent did not include information on the right to cancel or instructions on how to cancel for 20 students/parents. Cause and Effect - The University did not have a control in place to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans included in the borrower notifications. As a result, borrowers may not have been aware of their right to cancel and how to cancel their Federal Direct Loans. Recommendation - The University should implement controls to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans are properly included in the borrower notifications. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Missing notifications to students were a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents did not begin until summer 2023, with an automated procedure being implemented in the fall 2023 semester.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-004 Criteria - Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program and how and when those funds will be disbursed. If those funds include Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Federal Direct Loans, the institution must notify the student or parent of the following: (i) The anticipated date and amount of the disbursement (ii) The student's or parent's right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the secretary (iii) The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement Condition - The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 50 students tested for eligibility with Federal Direct Loans, the disbursement notification sent to the student and/or parent did not include information on the right to cancel or instructions on how to cancel for 20 students/parents. Cause and Effect - The University did not have a control in place to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans included in the borrower notifications. As a result, borrowers may not have been aware of their right to cancel and how to cancel their Federal Direct Loans. Recommendation - The University should implement controls to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans are properly included in the borrower notifications. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Missing notifications to students were a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents did not begin until summer 2023, with an automated procedure being implemented in the fall 2023 semester.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 and Federal Pell Grants ALN 84.063 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-001 Criteria - Changes in a student’s status are required to be reported to the National Student Loan Data System (NSLDS) within 30 days of the change or included in a student status confirmation report sent to the NSLDS within 60 days of the status change (Pell, 34 CFR Section 690.83(b); Direct Loan, 34 CFR Section 685.309(b)). Condition - The University did not report the status changes of certain students to the NSLDS in an accurate and timely manner during the fiscal year. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - There were three errors identified that were attributed to this finding: 1) Of the 60 students tested, there were 5 students who withdrew/graduated whose status changes were not reported to the NSLDS within 60 days. 2) Of the 60 students tested, there were 7 students who withdrew/graduated whose status changes were not reported to the NSLDS. 3) Of the 60 students tested, there was 1 student who withdrew whose status change was not reported accurately to the NSLDS. The student withdrew and was reported with an incorrect effective date. Cause and Effect - The University did not have a control in place to ensure all enrollment changes are reported timely and accurately to the NSLDS. As a result, certain student status changes were not reported to the NSLDS in a timely and accurate manner. Recommendation - The University should implement controls to ensure student status changes are reported accurately and timely to the NSLDS. These controls should include a thorough review of the enrollment rosters prior to reporting to the NSLDS. Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The University is submitting the data to the NSLDS via the clearinghouse in the required time frame. Certain status changes took place after the standard reporting cycle and were not picked up in this process. New processes have been established to identify and report these status changes to the NSLDS that take place after the standard reporting cycle.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster Federal Direct Student Loan Program ALN 84.268, Federal Pell Grants ALN 84.063, and Federal Supplemental Education Opportunity Grant ALN 84.007 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-003 Criteria - If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance but before he or she has attended 60 percent of the scheduled length of the semester, the school must perform a return of Title IV funds (R2T4) calculation. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. A school must return unearned funds for which it is responsible no later than 45 days from the determination of a student's withdrawal (30 days if never attended) (34 CFR 668.22(j)(1)). When a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If an institution does not require instructors to take attendance, the withdrawal date is (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss, or other circumstances beyond the student’s control, the date the institution determines is related to that circumstance; (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Notwithstanding the above, an institution that is not required to take attendance may use as the withdrawal date the last date of attendance at an academically related activity, as documented by the institution (34 CFR668.22(c) and (l)). Condition - The University used inaccurate or incomplete data in the return of Title IV calculations. Questioned Costs - $(1,446) Identification of How Questioned Costs Were Computed - Recalculation of returns was based on accurate student data. Context - There were three errors that were attributed to this finding: 1) Of the 60 students tested, there were 3 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended) 2) Of the 60 students tested, there were 5 students identified where the University completed the R2T4 calculation but the calculation was not completed accurately, resulting in a net of $(1,446) in questioned costs. 3) Of the 60 students tested, noted inconsistency in process in determining if there was an academically related activity that would better reflect the withdrawal date used in the return to Title IV calculation. Cause and Effect - The University did not have a control in place to ensure all returns of Title IV refunds are initiated timely and accurately. As a result, certain student Title IV refund calculations were not completed in a timely and accurate manner. Recommendation - The University should implement controls to ensure returns of Title IV refunds are initiated timely and accurately. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. The failure to return funds in a timely fashion is primarily a result of university withdrawal policy not aligning with the timelines required by the regulations. To that end, the University is revising its policies and procedures, specifically as they relate to medical withdrawals and for programs where attendance is required. As of June 2023, the University now has reports that identify all the affected students in a timely fashion. Additional resources have been allocated to assure that there is consistency and timeliness in the review of enrollment data specifically as it relates to determining attendance in dropped courses and students who rescind their intent to withdraw or enroll in or attend subsequent modules.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-004 Criteria - Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program and how and when those funds will be disbursed. If those funds include Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Federal Direct Loans, the institution must notify the student or parent of the following: (i) The anticipated date and amount of the disbursement (ii) The student's or parent's right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the secretary (iii) The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement Condition - The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 50 students tested for eligibility with Federal Direct Loans, the disbursement notification sent to the student and/or parent did not include information on the right to cancel or instructions on how to cancel for 20 students/parents. Cause and Effect - The University did not have a control in place to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans included in the borrower notifications. As a result, borrowers may not have been aware of their right to cancel and how to cancel their Federal Direct Loans. Recommendation - The University should implement controls to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans are properly included in the borrower notifications. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Missing notifications to students were a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents did not begin until summer 2023, with an automated procedure being implemented in the fall 2023 semester.

Assistance Listing Number, Federal Agency, and Program Name - Student Financial Assistance Cluster - Federal Direct Student Loan Program ALN 84.268 Federal Award Identification Number and Year - Various Pass-through Entity - None Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2022-004 Criteria - Before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program and how and when those funds will be disbursed. If those funds include Direct Loan Program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans. Except in the case of a post-withdrawal disbursement made in accordance with Sec. 668.22(a)(5), if an institution credits a student's account at the institution with Federal Direct Loans, the institution must notify the student or parent of the following: (i) The anticipated date and amount of the disbursement (ii) The student's or parent's right to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the secretary (iii) The procedures and the time by which the student or parent must notify the institution that he or she wishes to cancel the loan or loan disbursement Condition - The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - Of the 50 students tested for eligibility with Federal Direct Loans, the disbursement notification sent to the student and/or parent did not include information on the right to cancel or instructions on how to cancel for 20 students/parents. Cause and Effect - The University did not have a control in place to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans included in the borrower notifications. As a result, borrowers may not have been aware of their right to cancel and how to cancel their Federal Direct Loans. Recommendation - The University should implement controls to ensure information on the right to cancel or instructions on how to cancel Federal Direct Loans are properly included in the borrower notifications. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding. Missing notifications to students were a result of a coding error in the automated process that was resolved on September 5, 2023. Notifications to parents did not begin until summer 2023, with an automated procedure being implemented in the fall 2023 semester.