Audit 297264

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution did not perform their due diligence for fiscal year 2023. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: No Auditor’s Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 1) There was no review process in place for R2T4 calculations. 2) 14 of 60 students tested did not returned funds within 45 days. 3) 5 out of 60 students tested resulted in $4,974 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. Questioned Costs: $4,974 Context: The University had instances where students left the school but the University incorrectly performed a R2T4 calculation and under returned federal funds. Cause: The University has had turnover and there was no oversight over the withdrawal process and calculation of R2T4 which includes review of the R2T4 calculations. Effect: There are questioned costs of $4,974. Additionally, with no review in place, there could be potential for additional R2T4 amounts not being calculated appropriately. Repeat Finding: Yes, Finding 2022-001. Auditors’ Recommendation We recommend that the University implement a review process as it relates to R2T4 calculations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 24 of 60 students effective date per the institutions record and the NSLDS effective date not to match. The University did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 12 out of 60 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The University has had turnover and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes, Finding 2022-002. Auditor’s Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.165, states Direct Loans or TEACH funds are being credited to a student’s account, the institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement (a minimum of 14 or 30 days depending on confirmation process). The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Condition: Due to a gap in their systems, there were no notifications of disbursements sent out to students in the fiscal year. As well as one Pell COD disbursement incorrectly reported. We noted the disbursement date did not match the applied date. Questioned Costs: None Context: The University had an issue with their reporting for eligibility. Cause: Lack of controls around reporting with in SFA. Effect: The University was not in compliance with the requirements to timely respond to errors. Repeat Finding: No Auditor’s Recommendation: We recommend that the University review their controls around eligibility. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. In addition, the Code of Federal Regulations, 34 CFR 673.5, states students may not be awarded need based aid in excess of their calculated need. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized direct loan funds and one of 40 students tested was under awarded subsidized direct loan funds. Questioned Costs: $1,321 Context: The University had instances where they over and under awarded there students due to not evaluating the status of the students each semester. Cause: Lack of controls around awarding with in SFA. Effect: There are questioned costs of $1,321. Repeat Finding: No Auditor’s Recommendation: We recommend the University evaluate the students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program for institutions with fewer than 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Condition: There were a few missing items from the Written Information Security Program. Questioned Costs: N/A Context: These new GLBA requirements were applicable beginning on June 9, 2023 and there a few elements were missing from their WISP. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The student personal information could be vulnerable. Repeat Finding: No Auditor’s Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2022 to June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution did not perform their due diligence for fiscal year 2023. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: No Auditor’s Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.