Audit 297438

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.

Special Tests and Provisions - Return to Title IV Program Name: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements 34 CFR section 668.173(b) Returns of Title IV (R2T4) funds are required to be deposited or transferred into the Student Financial Aid (SFA) account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Returns by check are late if the check is issued more than 45 days after the institution determined the student withdrew or the date on the canceled check shows the check was endorsed more than 60 days after the date the institution determined that the student withdrew. Condition Significant Deficiency in Internal Control over Compliance – During testing over Return to Title IV requirements, 7 of 60 Return to Title IV calculations did not have funds returned within the 45-day requirement. Questioned Costs There are no questioned costs associated with the condition identified. All funds were returned, however, not within the 45 day requirement. Context We tested a non-statistical sample of 60 R2T4 calculations of a total 277 calculations performed by the District during the 2023 aid year. Effect Without proper monitoring of the timing of student withdrawals and calculations of R2T4, the District risks noncompliance with the above referenced criteria. Cause The District did not implement procedures to ensure that the return to Title IV funds were returned in a timely manner. Recommendation The District should establish effective controls to ensure the return of funds occurs within 45 days from the date the institution determines the student withdrew from all classes.

Special Tests and Provisions – Enrollment Reporting Program Name: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.033, 84.063, and 84.268 Federal Agency: U.S. Department of Education (ED) Direct funded by the U.S. Department of Education (ED) Criteria or Specific Requirements OMB Compliance Supplement, OMB No. 1845-0035 – Institutions are required to report enrollment information under the Pell grant, the Federal Direct Loan and Federal Family Education Loan (FFEL) programs via the National Student Loan Data System (NSLDS). Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via 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 identified above, and submit the changes electronically through the batch method, spreadsheet submittal, or the NSLDS website (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309: Perkins 34 CFR 674.19(f)). Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institutions’ Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Condition Significant Deficiency in Internal Control over Compliance – During testing over the NSLDS reporting requirements we noted 2 of 42 student tested did not report withdrawal dates to NSLDS. Questioned Costs There are no questioned costs associated with the noncompliance. Context We tested a non-statistical sample of 42 status changes of a total 198 changes reported by the District during the 2023 aid year. Effect The District is not in compliance with the Federal enrollment reporting requirements described in the OMB Compliance Supplement. Cause The District did not report enrollment information for students that withdrew under the Pell Grant and Direct Loan Programs via NSLDS timely or accurately. Recommendation The District should implement a process to review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website.