Audit 303243

Reference Number 2023-002 Finding: Reporting Federal Assistance Listing Number 84.425E & 84.425F - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion & HEERF Institutional Portion Department of Education Award Number – P425E201050, P425F202411, P425L200337 Award Year 2023 Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to Alliance University and Subsidiary (the University) under the Higher Education Emergency Relief Fund (HEERF) Program. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report. Condition: The reporting frequency of the University’s required Student Aid and Institutional quarterly portion reporting requirements were not consistent with the existing federal requirements. Additionally, one out of the four quarterly Student Aid and Institutional Portion reports were made publicly available on the University’s website. Context: Four out of the eight required quarterly Student Aid and Institutional reports for fiscal year 2023 were tested to determine whether the reports were posted on the University’s website by the federal due dates and complied with federal regulations. Effect: The University and federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the grant award notification. Cause: Though the University had established internal controls in place to ensure it complied with the HEERF grant reporting requirements, due to turnover in key management, the procedures and controls in place for the required quarterly reports to be prepared, reviewed for accuracy, and be publicly posted within federally required timeframes, was not performed. Additionally, the University did not have adequate cross-training in place to ensure that reporting requirements were met after turnover occurred during the fiscal year. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the University strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund reporting requirements and to develop policies and procedures for staying abreast of the specific reporting requirements. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number 2023-002 Finding: Reporting Federal Assistance Listing Number 84.425E & 84.425F - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion & HEERF Institutional Portion Department of Education Award Number – P425E201050, P425F202411, P425L200337 Award Year 2023 Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to Alliance University and Subsidiary (the University) under the Higher Education Emergency Relief Fund (HEERF) Program. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report. Condition: The reporting frequency of the University’s required Student Aid and Institutional quarterly portion reporting requirements were not consistent with the existing federal requirements. Additionally, one out of the four quarterly Student Aid and Institutional Portion reports were made publicly available on the University’s website. Context: Four out of the eight required quarterly Student Aid and Institutional reports for fiscal year 2023 were tested to determine whether the reports were posted on the University’s website by the federal due dates and complied with federal regulations. Effect: The University and federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the grant award notification. Cause: Though the University had established internal controls in place to ensure it complied with the HEERF grant reporting requirements, due to turnover in key management, the procedures and controls in place for the required quarterly reports to be prepared, reviewed for accuracy, and be publicly posted within federally required timeframes, was not performed. Additionally, the University did not have adequate cross-training in place to ensure that reporting requirements were met after turnover occurred during the fiscal year. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the University strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund reporting requirements and to develop policies and procedures for staying abreast of the specific reporting requirements. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number 2023-002 Finding: Reporting Federal Assistance Listing Number 84.425E & 84.425F - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion & HEERF Institutional Portion Department of Education Award Number – P425E201050, P425F202411, P425L200337 Award Year 2023 Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to Alliance University and Subsidiary (the University) under the Higher Education Emergency Relief Fund (HEERF) Program. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report. Condition: The reporting frequency of the University’s required Student Aid and Institutional quarterly portion reporting requirements were not consistent with the existing federal requirements. Additionally, one out of the four quarterly Student Aid and Institutional Portion reports were made publicly available on the University’s website. Context: Four out of the eight required quarterly Student Aid and Institutional reports for fiscal year 2023 were tested to determine whether the reports were posted on the University’s website by the federal due dates and complied with federal regulations. Effect: The University and federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the grant award notification. Cause: Though the University had established internal controls in place to ensure it complied with the HEERF grant reporting requirements, due to turnover in key management, the procedures and controls in place for the required quarterly reports to be prepared, reviewed for accuracy, and be publicly posted within federally required timeframes, was not performed. Additionally, the University did not have adequate cross-training in place to ensure that reporting requirements were met after turnover occurred during the fiscal year. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the University strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund reporting requirements and to develop policies and procedures for staying abreast of the specific reporting requirements. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number 2023-002 Finding: Reporting Federal Assistance Listing Number 84.425E & 84.425F - Higher Education Emergency Relief Fund (HEERF) Student Aid Portion & HEERF Institutional Portion Department of Education Award Number – P425E201050, P425F202411, P425L200337 Award Year 2023 Criteria: The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020 and appropriated federal funds to provide economic aid to the American people negatively impacted by the COVID-19 pandemic. As part of the CARES Act, funds were given to Alliance University and Subsidiary (the University) under the Higher Education Emergency Relief Fund (HEERF) Program. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), was signed into law on December 27, 2020, and authorized additional funding under the HEERF program (HEERF II). Finally, the American Rescue Plan Act of 2021 (ARP), enacted on March 11, 2021, authorized a third round of funding (HEERF III) in order for higher education institutions to serve students and ensure learning continues during the COVID-19 pandemic. Under the requirements of the HEERF program there are three components to reporting: (1) public reporting on the Student Aid Portion; (2) public reporting on the Institutional Portion, and (3) the annual report. Condition: The reporting frequency of the University’s required Student Aid and Institutional quarterly portion reporting requirements were not consistent with the existing federal requirements. Additionally, one out of the four quarterly Student Aid and Institutional Portion reports were made publicly available on the University’s website. Context: Four out of the eight required quarterly Student Aid and Institutional reports for fiscal year 2023 were tested to determine whether the reports were posted on the University’s website by the federal due dates and complied with federal regulations. Effect: The University and federal oversight agencies, including the Department of Education, depend on accurate reports posted to the institution's website to measure program results and compliance with federal requirements and to provide transparency. By failing to report the HEERF spending information in accordance with federal regulations, the University failed to comply with the requirements of the grant award notification. Cause: Though the University had established internal controls in place to ensure it complied with the HEERF grant reporting requirements, due to turnover in key management, the procedures and controls in place for the required quarterly reports to be prepared, reviewed for accuracy, and be publicly posted within federally required timeframes, was not performed. Additionally, the University did not have adequate cross-training in place to ensure that reporting requirements were met after turnover occurred during the fiscal year. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the University strengthen its internal controls over reporting and ensure it complies with the Higher Education Emergency Relief Fund reporting requirements and to develop policies and procedures for staying abreast of the specific reporting requirements. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Reference Number: 2023-003 Finding: Special Tests & Provisions - Return of Title IV Funds Student Financial Assistance Cluster: Federal Assistance Listing Numbers: 84.063 Federal Pell Grant Program 84.007 Federal Supplemental Educational Opportunity Grants 84.268 Federal Direct Student Loans Department of Education Award Year 2022 – 2023 Criteria or Specific Requirement: When a recipient of Title IV assistance withdraws during a payment period or period of enrollment, the College must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student, the difference must be returned to the Title IV programs. The return must occur as soon as possible, but no later than 45 days after the date of the determination that the student withdrew. Code of Federal Regulations Title 34 Part 668 Section 22, Treatment of Title IV Funds outlines the requirements for calculating the amount of assistance earned by the student as of the withdrawal date, as well as the timeframe and the order in which funds are required to be returned to the various Title IV assistance program. Condition: Out of the population of 44 students who received federal student financial assistance but withdrew or dropped out during the year, a sample of 10 students were selected for testing. One returns of Title IV calculations was not returned within 45 days after the date became aware of the withdrawal, which resulted in Title IV, consisting of Federal Pell Grant, FSEOG, and Federal Direct Student Loan funds, not remitted to the respective programs timely. Context: We tested 10 out of the 44 Return of Title IV Funds calculations performed during the fiscal year 2023. Our sample was not, and was not intended to be, statistically valid. Effect: The return of a student’s Title IV funding was not returned to the Department of Education within the specified 45-day.   Reference Number Finding Cause: Due to management oversight, though the student financial service department was notified of the non-voluntary withdrawal, the student was missed in determining the Title IV amount to be returned. Upon periodic review of the withdrawal log by the Student Financial Services Director, the student’s calculation of return of Title IV was determined and amounts were subsequently returned to the respective programs. Identification as a Repeat Finding: Not applicable. Recommendation: We acknowledge that both issues were internally identified and corrected by the College prior to year-end. However, we recommend that the College continue to enhance policies and procedures over this requirement to ensure proper information is used, and a timely review is completed, at the time of initial calculation, to help ensure the proper amount is returned to the Department of Education within the required time frame. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.