Audit 300758

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2023: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days and with an accurate effective date of the student enrollment change. During our testing, we noted 2 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS. Cause The College’s policy is to report graduated students to the NSLDS effective as of the last day of classes per the College’s academic calendar. For Fall 2022 and Spring 2023, the last day of classes was December 20, 2022 and May 8, 2023, respectively. The Registrar reported the effective date of a Fall 2022 graduate as December 31, 2022 and a Spring 2023 graduate as May 31, 2023. Effect The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had incorrect effective dates reported to NSLDS. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed below.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F, 84.425L Award year: 2023 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education’s G5 grants system (“G5”) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the College drew down the entire balance of the HEERF III Institutional Aid portion and HEERF III Minority Serving Institution portion but the balances were not spent by June 30, 2023. The balances were not expended within three calendar days of drawdown as required. This is a summary of the balances unspent at June 30, 2023: Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds and Minority Serving Institution Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds and Minority Serving Institution Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs 255,052 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable See finding 2022-001 included in the summary schedule of prior year findings. Recommendation We recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. We also recommend the College coordinate with the Department of Education to return the unspent HEERF funds with any applicable interest. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F, 84.425L Award year: 2023 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education’s G5 grants system (“G5”) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the College drew down the entire balance of the HEERF III Institutional Aid portion and HEERF III Minority Serving Institution portion but the balances were not spent by June 30, 2023. The balances were not expended within three calendar days of drawdown as required. This is a summary of the balances unspent at June 30, 2023: Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds and Minority Serving Institution Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds and Minority Serving Institution Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs 255,052 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable See finding 2022-001 included in the summary schedule of prior year findings. Recommendation We recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. We also recommend the College coordinate with the Department of Education to return the unspent HEERF funds with any applicable interest. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that – (i) A loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (“ED”) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2023: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days and with an accurate effective date of the student enrollment change. During our testing, we noted 2 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS. Cause The College’s policy is to report graduated students to the NSLDS effective as of the last day of classes per the College’s academic calendar. For Fall 2022 and Spring 2023, the last day of classes was December 20, 2022 and May 8, 2023, respectively. The Registrar reported the effective date of a Fall 2022 graduate as December 31, 2022 and a Spring 2023 graduate as May 31, 2023. Effect The College did not report the students’ correct effective dates to NSLDS, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had incorrect effective dates reported to NSLDS. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the effective date of a student’s withdrawal, the importance of reporting the correct effective date and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. View of Responsible Officials The College agrees with the finding and has implemented the corrective action plan listed below.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F, 84.425L Award year: 2023 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education’s G5 grants system (“G5”) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the College drew down the entire balance of the HEERF III Institutional Aid portion and HEERF III Minority Serving Institution portion but the balances were not spent by June 30, 2023. The balances were not expended within three calendar days of drawdown as required. This is a summary of the balances unspent at June 30, 2023: Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds and Minority Serving Institution Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds and Minority Serving Institution Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs 255,052 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable See finding 2022-001 included in the summary schedule of prior year findings. Recommendation We recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. We also recommend the College coordinate with the Department of Education to return the unspent HEERF funds with any applicable interest. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425F, 84.425L Award year: 2023 Criteria For Coronavirus Response and Relief Supplemental Appropriations Act HEERF II and American Rescue Plan Act HEERF III, the Certification and Agreements and/or Supplemental Agreements requires that Student Aid Portion (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from the Department of Education’s G5 grants system (“G5”) and Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. For lost revenue, the “obligation” occurs on the date the institution completes its estimate of its amount of lost revenue after the estimation period. Condition The Federal Government requires the College to disburse the Institutional Aid Portion of HEERF funds within three calendar days of drawdown from G5. During our testing, we noted that the College drew down the entire balance of the HEERF III Institutional Aid portion and HEERF III Minority Serving Institution portion but the balances were not spent by June 30, 2023. The balances were not expended within three calendar days of drawdown as required. This is a summary of the balances unspent at June 30, 2023: Cause Due to the inexperience with the HEERF III program, the College did not have adequate procedures in place to ensure that Institutional Aid Funds and Minority Serving Institution Funds were disbursed within three calendar days of drawdown. Effect HEERF III Institutional Aid Funds and Minority Serving Institution Funds were drawn down in excess of disbursements and the excess funds remained unspent beyond the three-calendar day threshold for institutional expenditures. Due to these circumstances, the College was not in compliance with the cash management requirement of the HEERF III agreements. Questioned Costs 255,052 Perspective Our sample was not, and was not intended to be, statistically valid. We selected one HEERF institutional drawdown to test and it was not disbursed within the required three-calendar day threshold. Identification as a Repeat Finding, if applicable See finding 2022-001 included in the summary schedule of prior year findings. Recommendation We recommend that the College implements procedures to ensure that future cash drawdowns occur within the required period before or after expending the grant funds. We also recommend the College coordinate with the Department of Education to return the unspent HEERF funds with any applicable interest. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund Assistance Listing #: 84.425E, 84.425F, 84.425L Award year: 2023 Criteria Question 36 of the Higher Education Emergency Relief Fund III Frequently Asked Questions required that beginning with the second quarter 2022 quarterly report (due July 10, 2022) institutions must complete and post on their websites Quarterly Reports using a new combined institutional and student reporting form. This requires that the institution detail quarterly expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition The Federal Government requires the College to accurately report quarterly expenditures and post the quarterly report to their website. During our testing, we noted that while the College properly posted their quarterly reports to their website, the expenditures per the quarterly reports did not reconcile with the institution’s underlying records. Cause Due to the inexperience with the HEERF III program and the use of temporary workers unfamiliar with the program’s requirements, the College’s underlying records did not reconcile to the expenditures on their HEERF quarterly reports. Effect The College's HEERF expenditures per the quarterly reports posted to their website were not accurate. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. We selected the four HEERF quarterly report to test and they did not reconcile to the underlying account records. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend the College create procedures to ensure College is in compliance with the program's quarterly reporting requirements. View of Responsible Officials The College agrees with the finding.