Audit 297283

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR Section 685.304 (a): 1. A school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS loan. Condition The Federal Government requires that entrance counseling is conducted with Direct Loan borrowers prior to their first disbursement. During our testing, we noted 3 students, out of a sample of 40, did not have evidence that entrance counseling was performed prior to their first loan disbursement. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to ensure that entrance counseling was conducted with Direct Loan borrowers prior to their first disbursement. Effect The College did not meet federal requirements and students did not complete entrance counseling before their first disbursements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-002 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure entrance counseling is completed for a student borrower before their first disbursement of their loan. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student, out of a sample of 40, that the amount of the funds credited to the student's account did not match with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed date in the student account did not align with the disbursed date in the COD by a range of 1-5 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement amount and disbursement date per the student's account statement matched the disbursement amount and disbursement date reported to COD. Effect The College did not report the correct disbursement amount and date to the COD. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student, out of a sample of 40, that the amount of the funds credited to the student's account did not match with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed date in the student account did not align with the disbursed date in the COD by a range of 1-5 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement amount and disbursement date per the student's account statement matched the disbursement amount and disbursement date reported to COD. Effect The College did not report the correct disbursement amount and date to the COD. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR Section 685.303 (b)(5)(i): If a student is enrolled in the first year of an undergraduate program of study and has not previously received a Direct Subsidized Loan, a Direct Unsubsidized Loan, a Subsidized or Unsubsidized Federal Stafford Loan, or a Federal Supplemental Loan for Students, a school may not disburse the proceeds of a Direct Subsidized or Direct Unsubsidized Loan until 30 days after the first day of the student's program of study unless- (A) (1) Except as provided in paragraph (b)(5)(i)(A)(2) of this section, the school has a cohort default rate, calculated under subpart M of 34 CFR part 668, or weighted average cohort rate of less than 10 percent for each of the three most recent fiscal years for which data are available; or (2) For loans first disbursed on or after October 1, 2011, the school in which the student is enrolled has a cohort default rate, calculated under either subpart M or N of 34 CFR part 668 of less than 15 percent for each of the three most recent fiscal years for which data are available; (B) The school is an eligible home institution originating a loan to cover the cost of attendance in a study abroad program and has a Direct Loan Program cohort rate, FFEL cohort default rate, or weighted average cohort rate of less than 5 percent for the single most recent fiscal year for which data are available. Condition The Federal Government requires the College not to disburse the first installment of Direct loans to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. During our testing, we noted 3 students, out of a sample of 40, who had not previously received direct loans and were disbursed loans within the first 30 days after the student’s first day of classes. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that Direct loans were not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. Effect The College disbursed loans to students before they were eligible to receive them. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal controls to ensure that Direct loans are not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days after the date issued. During our testing, we noted one student that had unclaimed funds exceeding the federal day limit by 53 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check that totaled $634, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2021-004 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agree with the finding.

Finding number: 2022-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 6 students were reported late to the NSLDS by 4 to124 days and 2 out of 6 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 6 students were reported late to the NSLDS by 4 to124 days and 2 out of 6 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. For a sample of 3 months, during our testing, 2 months had discrepancies that were not resolved in a timely manner. Our sample was not, and was not intended to be, statistically valid. We noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. However, we noted that the College performed the year end reconciliation and noted no discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-005 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (1) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 15 students, out of a sample of 40, that were not refunded credit balances within the required timeframe by 1-14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College failed to refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should implement effective internal controls to identify credit balances and refund federal aid to students within the required timeframes. This includes reviewing accounts after late disbursements of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (1) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 15 students, out of a sample of 40, that were not refunded credit balances within the required timeframe by 1-14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College failed to refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should implement effective internal controls to identify credit balances and refund federal aid to students within the required timeframes. This includes reviewing accounts after late disbursements of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR Section 685.304 (a): 1. A school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized Loan, Direct Unsubsidized Loan, Subsidized or Unsubsidized Federal Stafford Loan, or Federal SLS loan. Condition The Federal Government requires that entrance counseling is conducted with Direct Loan borrowers prior to their first disbursement. During our testing, we noted 3 students, out of a sample of 40, did not have evidence that entrance counseling was performed prior to their first loan disbursement. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to ensure that entrance counseling was conducted with Direct Loan borrowers prior to their first disbursement. Effect The College did not meet federal requirements and students did not complete entrance counseling before their first disbursements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-002 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure entrance counseling is completed for a student borrower before their first disbursement of their loan. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.007, and 84.268 Award year: 2022 Compliance Requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 4 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student, out of a sample of 40, that the amount of the funds credited to the student's account did not match with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed date in the student account did not align with the disbursed date in the COD by a range of 1-5 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement amount and disbursement date per the student's account statement matched the disbursement amount and disbursement date reported to COD. Effect The College did not report the correct disbursement amount and date to the COD. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b) (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2021-2022 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 1 student, out of a sample of 40, that the amount of the funds credited to the student's account did not match with the COD disbursed amount. Additionally, for 3 students, out of a sample of 40, the disbursed date in the student account did not align with the disbursed date in the COD by a range of 1-5 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement amount and disbursement date per the student's account statement matched the disbursement amount and disbursement date reported to COD. Effect The College did not report the correct disbursement amount and date to the COD. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR Section 685.303 (b)(5)(i): If a student is enrolled in the first year of an undergraduate program of study and has not previously received a Direct Subsidized Loan, a Direct Unsubsidized Loan, a Subsidized or Unsubsidized Federal Stafford Loan, or a Federal Supplemental Loan for Students, a school may not disburse the proceeds of a Direct Subsidized or Direct Unsubsidized Loan until 30 days after the first day of the student's program of study unless- (A) (1) Except as provided in paragraph (b)(5)(i)(A)(2) of this section, the school has a cohort default rate, calculated under subpart M of 34 CFR part 668, or weighted average cohort rate of less than 10 percent for each of the three most recent fiscal years for which data are available; or (2) For loans first disbursed on or after October 1, 2011, the school in which the student is enrolled has a cohort default rate, calculated under either subpart M or N of 34 CFR part 668 of less than 15 percent for each of the three most recent fiscal years for which data are available; (B) The school is an eligible home institution originating a loan to cover the cost of attendance in a study abroad program and has a Direct Loan Program cohort rate, FFEL cohort default rate, or weighted average cohort rate of less than 5 percent for the single most recent fiscal year for which data are available. Condition The Federal Government requires the College not to disburse the first installment of Direct loans to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. During our testing, we noted 3 students, out of a sample of 40, who had not previously received direct loans and were disbursed loans within the first 30 days after the student’s first day of classes. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that Direct loans were not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. Effect The College disbursed loans to students before they were eligible to receive them. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement internal controls to ensure that Direct loans are not disbursed to first-year undergraduates who are first time borrowers until 30 days after the student’s first day of classes. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days after the date issued. During our testing, we noted one student that had unclaimed funds exceeding the federal day limit by 53 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check that totaled $634, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2021-004 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The Colleges agree with the finding.

Finding number: 2022-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 6 students were reported late to the NSLDS by 4 to124 days and 2 out of 6 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 4 out of 6 students were reported late to the NSLDS by 4 to124 days and 2 out of 6 students reported an incorrect effective date to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-006 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. For a sample of 3 months, during our testing, 2 months had discrepancies that were not resolved in a timely manner. Our sample was not, and was not intended to be, statistically valid. We noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. However, we noted that the College performed the year end reconciliation and noted no discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2021-005 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (1) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 15 students, out of a sample of 40, that were not refunded credit balances within the required timeframe by 1-14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College failed to refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should implement effective internal controls to identify credit balances and refund federal aid to students within the required timeframes. This includes reviewing accounts after late disbursements of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2022-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 and 84.268 Award year: 2022 Compliance Requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (1) A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than – (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 15 students, out of a sample of 40, that were not refunded credit balances within the required timeframe by 1-14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College failed to refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable Recommendation The Business Office should implement effective internal controls to identify credit balances and refund federal aid to students within the required timeframes. This includes reviewing accounts after late disbursements of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.