Audit 300242

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change was received by NSLDS was outside of the 60-day timeframe: • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 4 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 24 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222130, P268K232130, P063P212130, and P063P222130): 3 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2022-002 Kutztown University – Yes – Finding 2022-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 7 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 1 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 6 of the 40 students tested for award year 2022-23 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 3 of the 40 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 40 students tested for award year 2022-23 3) Incorrect Program Enrollment Status Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student's program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 004 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Notification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition and Context: During our testing of Common Origination and Disbursement (COD) system reporting on the State System, we noted: 1) Disbursements reported outside of the 15 day timeframe • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 disbursements tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 8 disbursements tested for award year 2022-23 2) Disbursements reported with incorrect disbursement dates • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 2 of the 40 disbursements tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that aid disbursement information was timely and accurately reported to COD. Effect: The errors identified above relate to Pell Grant disbursement reporting; however, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculations as students’ interest accrues based on the disbursement date reported to COD. Repeat Finding: Kutztown University – Yes – Finding 2022-006 All Other Universities – No Recommendation: The Universities should review their policies and procedures around COD reporting to ensure students’ information is reporting timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change was received by NSLDS was outside of the 60-day timeframe: • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 4 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 24 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222130, P268K232130, P063P212130, and P063P222130): 3 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2022-002 Kutztown University – Yes – Finding 2022-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 7 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 1 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 6 of the 40 students tested for award year 2022-23 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 3 of the 40 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 40 students tested for award year 2022-23 3) Incorrect Program Enrollment Status Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student's program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 004 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Notification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition and Context: During our testing of Common Origination and Disbursement (COD) system reporting on the State System, we noted: 1) Disbursements reported outside of the 15 day timeframe • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 disbursements tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 8 disbursements tested for award year 2022-23 2) Disbursements reported with incorrect disbursement dates • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 2 of the 40 disbursements tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that aid disbursement information was timely and accurately reported to COD. Effect: The errors identified above relate to Pell Grant disbursement reporting; however, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculations as students’ interest accrues based on the disbursement date reported to COD. Repeat Finding: Kutztown University – Yes – Finding 2022-006 All Other Universities – No Recommendation: The Universities should review their policies and procedures around COD reporting to ensure students’ information is reporting timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 005 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K222133 and P268K232133; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During the testing of Direct Loan Reconciliations on the State System, we noted that East Stroudsburg University was performing reconciliations; however, formal documentation of review or approval could not be provided. Questioned Costs: N/A Cause: The University financial and student records management did not have the appropriate coordination or communication with the financial aid team to formally document the review of the reconciliations being performed on a timely basis. Effect: The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled. Repeat Finding: No Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 001 Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; Award Year 2021-22 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the section 2003(a)(1) Student Aid Portion; 2) public reporting on the section 2003(a)(1) Institutional Portion section 2003(a)(2) and section 2003(a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition and Context: During our testing of HEERF reporting requirements on the State System, we noted: 1) Noncompliant Reporting: • Cheyney University (P425E202680 and P425F201194): Two of the two quarterly reports and the annual report selected for testing were not uploaded to the University’s website timely. • Pennsylvania Western University (P425E200998): The one quarterly report and the annual report selected for testing were not able to be provided as proof of completion. Questioned Costs: N/A Cause: The policies and procedures of the Universities are not designed to ensure that grant reporting requirements were timely met. Effect: The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: Cheyney University – Yes – Finding 2022-001 Pennsylvania Western University – Yes – Finding 2022-001 Recommendation: The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 001 Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; Award Year 2021-22 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the section 2003(a)(1) Student Aid Portion; 2) public reporting on the section 2003(a)(1) Institutional Portion section 2003(a)(2) and section 2003(a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition and Context: During our testing of HEERF reporting requirements on the State System, we noted: 1) Noncompliant Reporting: • Cheyney University (P425E202680 and P425F201194): Two of the two quarterly reports and the annual report selected for testing were not uploaded to the University’s website timely. • Pennsylvania Western University (P425E200998): The one quarterly report and the annual report selected for testing were not able to be provided as proof of completion. Questioned Costs: N/A Cause: The policies and procedures of the Universities are not designed to ensure that grant reporting requirements were timely met. Effect: The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: Cheyney University – Yes – Finding 2022-001 Pennsylvania Western University – Yes – Finding 2022-001 Recommendation: The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change was received by NSLDS was outside of the 60-day timeframe: • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 4 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 24 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222130, P268K232130, P063P212130, and P063P222130): 3 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2022-002 Kutztown University – Yes – Finding 2022-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 7 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 1 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 6 of the 40 students tested for award year 2022-23 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 3 of the 40 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 40 students tested for award year 2022-23 3) Incorrect Program Enrollment Status Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student's program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 004 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Notification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition and Context: During our testing of Common Origination and Disbursement (COD) system reporting on the State System, we noted: 1) Disbursements reported outside of the 15 day timeframe • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 disbursements tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 8 disbursements tested for award year 2022-23 2) Disbursements reported with incorrect disbursement dates • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 2 of the 40 disbursements tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that aid disbursement information was timely and accurately reported to COD. Effect: The errors identified above relate to Pell Grant disbursement reporting; however, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculations as students’ interest accrues based on the disbursement date reported to COD. Repeat Finding: Kutztown University – Yes – Finding 2022-006 All Other Universities – No Recommendation: The Universities should review their policies and procedures around COD reporting to ensure students’ information is reporting timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 002 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition and Context: During our testing of NSLDS Enrollment Reporting on the State System, we noted: 1) Status change was received by NSLDS was outside of the 60-day timeframe: • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 4 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 24 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222130, P268K232130, P063P212130, and P063P222130): 3 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that student status changes were timely reported to NSLDS. Effect: The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Repeat Finding: Cheyney University – Yes – Finding 2022-002 Kutztown University – Yes – Finding 2022-002 All Other Universities – No Recommendation: The Universities should review their reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 003 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Numbers: 84.063 and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 34 CFR 685.309(b), states that: 1) Schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. 2) Schools must have some arrangement to report student program enrollment effective date and status to NSLDS. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of enrollment status reporting on the State System, we noted: 1) Incorrect Enrollment Effective Date Reported to NSLDS • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 7 of the 40 students tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 1 of the 5 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 6 of the 40 students tested for award year 2022-23 2) Incorrect Program Enrollment Effective Date Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 • East Stroudsburg University (P268K222133, P268K232133, P063P212133, and P063P222133): 3 of the 40 students tested for award year 2022-23 • Cheyney University (P268K222131, P268K232131, P063P212131, and P063P222131): 1 of the 40 students tested for award year 2022-23 3) Incorrect Program Enrollment Status Reported to NSLDS • Lock Haven University (P268K222136, P268K232136, P063P212136, and P063P222136): 1 of the 5 students tested for award year 2022-23 • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 students tested for award year 2022-23 Questioned Costs: N/A Causes: 1) The Universities did not have a process in place to ensure the effective date reported to NSLDS matches the effective date of the student’s last date of attendance. 2) The Universities did not have a process in place to ensure the student's program enrollment effective date was being accurately reported. 3) The Universities did not have a process in place to ensure the student's program enrollment status was being accurately reported. Effect: 1) The enrollment effective date reported to NSLDS is used to determine when the student’s grace period should begin. By not reporting a correct effective date, the grace period begin date for the student will be incorrect. 2) The program enrollment effective date reported to NSLDS is used to determine the student’s 150% limit for direct loans as well as when grace period should begin. By not reporting the correct status, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. Repeat Finding: Cheyney University – Yes – Finding 2022-003 Kutztown University – Yes – Finding 2022-003 All Other Universities – No Recommendation: 1) The Universities should evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the Universities’ last date of attendance. 2) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. 3) The Universities should evaluate their procedures and review policies surrounding reporting program enrollment statuses to NSLDS. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 004 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 and 84.268 Federal Award Notification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition and Context: During our testing of Common Origination and Disbursement (COD) system reporting on the State System, we noted: 1) Disbursements reported outside of the 15 day timeframe • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 1 of the 40 disbursements tested for award year 2022-23 • Kutztown University (P268K222135, P268K232135, P063P212135, and P063P222135): 5 of the 8 disbursements tested for award year 2022-23 2) Disbursements reported with incorrect disbursement dates • West Chester University (P268K222141, P268K232141, P063P212141, and P063P222141): 2 of the 40 disbursements tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities’ policies and procedures were not designed to ensure that aid disbursement information was timely and accurately reported to COD. Effect: The errors identified above relate to Pell Grant disbursement reporting; however, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculations as students’ interest accrues based on the disbursement date reported to COD. Repeat Finding: Kutztown University – Yes – Finding 2022-006 All Other Universities – No Recommendation: The Universities should review their policies and procedures around COD reporting to ensure students’ information is reporting timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 005 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Identification Number and Year: P268K222133 and P268K232133; all grants were awarded within the 2021-22 and 2022-23 award years Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During the testing of Direct Loan Reconciliations on the State System, we noted that East Stroudsburg University was performing reconciliations; however, formal documentation of review or approval could not be provided. Questioned Costs: N/A Cause: The University financial and student records management did not have the appropriate coordination or communication with the financial aid team to formally document the review of the reconciliations being performed on a timely basis. Effect: The University is not complying with internal policy and federal requirements to ensure federal funds are properly reconciled. Repeat Finding: No Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the university policies and federal requirements related to monthly reconciliations and maintenance of documentation. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 006 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: In accordance with 34 CFR 668.22(a)(1), when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of Return of Title IV (R2T4) funding on the State System, we noted: 1) Calculations were not being performed timely, resulting in payments being returned outside of the 45 day timeframe • Pennsylvania Western University (P007A213550, P007A223550, P063P212130, P063P222130, P268K222130, and P268K232130): 2 of the 13 students tested for award year 2022-23 • Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131): 3 of the 6 students tested for award year 2022-23 Questioned Costs: N/A Cause: The Universities were not timely tracking withdraws of students who were awarded Title IV aid, resulting in calculations being performed late. Effect: Funds could be returned late to either the Department of Education or late post-withdrawal disbursements to the students. Repeat Finding: No Recommendation: The Universities should review policies and procedures around tracking withdraws and timely performance of R2T4 calculations. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 007 Federal Agency: Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, and 84.268 Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; all grants were awarded within the 2021-22 and 2022-23 award years. Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Uniform Guidance requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) which must include the total federal awards expended as determined in accordance with sub-section 200.502. 2 CFR 200.510. The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. Condition and Context: During our testing of completeness of the SEFA for Cheyney University (P007A213558, P007A223558, P063P212131, P063P222131, P268K222131, and P268K232131) we noted approximately $3,000,000 of institutional aid expenditures were incorrectly included in the Student Financial Assistance Cluster. The error is a result of institutional aid expenditures being disallowed from the student financial assistance program and the SEFA not being subsequently updated. Questioned Costs: N/A Cause: The University did not timely update the SEFA and provide an updated version to the auditors. Effect: The SEFA contained errors in the balances reported for federal expenditures, which can cause the miscalculation of major programs and testing selections. Repeat Finding: No Recommendation: The University should review applicable guidance as well as its policies and procedures in place to ensure Federal grant and loan related activity is properly reflecting within the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 001 Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; Award Year 2021-22 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the section 2003(a)(1) Student Aid Portion; 2) public reporting on the section 2003(a)(1) Institutional Portion section 2003(a)(2) and section 2003(a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition and Context: During our testing of HEERF reporting requirements on the State System, we noted: 1) Noncompliant Reporting: • Cheyney University (P425E202680 and P425F201194): Two of the two quarterly reports and the annual report selected for testing were not uploaded to the University’s website timely. • Pennsylvania Western University (P425E200998): The one quarterly report and the annual report selected for testing were not able to be provided as proof of completion. Questioned Costs: N/A Cause: The policies and procedures of the Universities are not designed to ensure that grant reporting requirements were timely met. Effect: The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: Cheyney University – Yes – Finding 2022-001 Pennsylvania Western University – Yes – Finding 2022-001 Recommendation: The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.

2023 – 001 Federal Agency: Department of Education Federal Program Name: Education Stabilization Fund - Higher Education Emergency Relief Fund Assistance Listing Numbers: 84.425E and 84.425F Federal Award Identification Number and Year: See FAIN numbers included within the Context section below; Award Year 2021-22 Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for Higher Education Emergency Relief Fund (HEERF): 1) public reporting on the section 2003(a)(1) Student Aid Portion; 2) public reporting on the section 2003(a)(1) Institutional Portion section 2003(a)(2) and section 2003(a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition and Context: During our testing of HEERF reporting requirements on the State System, we noted: 1) Noncompliant Reporting: • Cheyney University (P425E202680 and P425F201194): Two of the two quarterly reports and the annual report selected for testing were not uploaded to the University’s website timely. • Pennsylvania Western University (P425E200998): The one quarterly report and the annual report selected for testing were not able to be provided as proof of completion. Questioned Costs: N/A Cause: The policies and procedures of the Universities are not designed to ensure that grant reporting requirements were timely met. Effect: The Universities are not complying with awarding requirements, which could affect the amount of Federal funding received. Repeat Finding: Cheyney University – Yes – Finding 2022-001 Pennsylvania Western University – Yes – Finding 2022-001 Recommendation: The Universities should review their policies and procedures around grant reporting to ensure all reporting requirements are met timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.