Audit 301124

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • In our sample of 40 students tested, 1 student was not reported to the NSLDS. • In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe. • In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • In our sample of 40 students tested, 1 student was not reported to the NSLDS. • In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe. • In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who ceases at least half-time study at the school. The Code of Federal Regulations, 34 CFR 674.16 requires institution to provide certain repayment information to students before making its first Perkins Loan disbursement to a student. 34 CFR 674.42 also requires exit counseling for all students who ceases at least half-time study at the school. Condition: During our testing, it was noted that some individuals did not receive exit counseling after their departure from the University. Questioned costs: None. Context: During our testing, it was noted that 2 out of 40 students did not receive exit counseling within the required 30 days of a student ceasing attendance. Cause: The University notes that these students graduated from their undergrad program in May of 2022. They then enrolled in a masters program and received new direct loans – they completed and graduated from these programs in May of 2023. Exit counseling was not sent after the May 2023 completion due to them completing such exit counseling in May 2022. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat finding: No. Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements. Questioned costs: None. Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat finding: No. Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • In our sample of 40 students tested, 1 student was not reported to the NSLDS. • In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe. • In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of your school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. The Department of Education requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Changes in enrollment status must be reported within 30 days. However, if a roster file is expected within 60 days, you may provide the date on that roster file. ED requires the institution to report changes in enrollment status within 30 or 60 days that the institution determined the changes occurred (34 CFR 682.610). Condition: Certain students’ enrollment information was not reported accurately or timely to the NSLDS. Questioned costs: None. Context: During our testing, we noted the following: • In our sample of 40 students tested, 1 student was not reported to the NSLDS. • In our sample of 40 students tested, 1 student was not reported timely within the 30 or 60 day timeframe. • In our sample of 40 students tested, 1 student did not have the correct enrollment effective date in the NSLDS at the program level. Cause: The University uses a third-party servicer to submit their enrollment reports to NSLDS. Occasionally, the third party incorrectly communicates information to NSLDS which results in discrepancies between the University’s system and NSLDS. The University has the ultimate responsibility to ensure that reporting is correct. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat finding: Yes, 2022-002. Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Direct Student Loans Assistance Listing Number: 84.268 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.304 require entrance counseling be performed before disbursing loan funds to the student for Direct Subsidized Loan, Direct Unsubsidized Loan and Direct PLUS Loan to a graduate or professional student. The regulations also require exit counseling for all students who ceases at least half-time study at the school. The Code of Federal Regulations, 34 CFR 674.16 requires institution to provide certain repayment information to students before making its first Perkins Loan disbursement to a student. 34 CFR 674.42 also requires exit counseling for all students who ceases at least half-time study at the school. Condition: During our testing, it was noted that some individuals did not receive exit counseling after their departure from the University. Questioned costs: None. Context: During our testing, it was noted that 2 out of 40 students did not receive exit counseling within the required 30 days of a student ceasing attendance. Cause: The University notes that these students graduated from their undergrad program in May of 2022. They then enrolled in a masters program and received new direct loans – they completed and graduated from these programs in May of 2023. Exit counseling was not sent after the May 2023 completion due to them completing such exit counseling in May 2022. Effect: Students are not receiving the proper loan counseling which may contribute to a higher default rate. Repeat finding: No. Recommendation: CLA recommends the University review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing Number: 84.038 Award Period: 7/1/2022 – 6/30/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service for its Perkins Loan servicing. This is a very common practice for colleges and universities in order to provide the most efficient and effective means to not only collect loans but meet the federal regulations for servicing student Perkins Loans. In order to perform the due diligence required per the Code of Regulations, the institution utilizes the external compliance report performed for the third party servicer by other auditors. The third party servicer’s compliance audit report for the year ended June 30, 2023 was not issued as of the report date of the uniform guidance report. Therefore, the University was unable to perform due diligence on the third party provider’s internal control over the Perkin’s requirements. Questioned costs: None. Context: We noted that the University was not able to obtain the third party’s compliance report as of the date of the Uniform Guidance Report. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2023 so that the University can perform their required due diligence on the third party servicer. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat finding: No. Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.