Audit 3046

Audit Finding Reference Number Questioned Cost 2022 - 002 - Return of Title IV Funds $28,431 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. ABC is a college that is not required to take attendance. Thus, ABC must determine the student’s withdrawal date as either (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstances, (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Conditions and Contexts During my audit, I noted the following: • ABC did not return the required Title IV funds within the prescribed timeframe for two (2) students out of six (6) tested. The amount required to be returned totaled $2,846, was not returned; • The Return of Title IV Funds calculation was prepared incorrectly for two (2) out of six (6) students tested. The incorrect calculations resulted in $1,990 in funds to be returned by ABC; • Attendance rosters tested in which ABC was unable to document the last date of attendance or participation in any academic related activity for each of the students’ enrolled courses and received all non-passing grades for eleven (11) of the eleven (11) students selected for testing resulting in $23,595 to be returned by ABC; and • Sixteen (16) students from a listing of 69 (sixty-nine) students received Title IV aid and withdrew but did not have a Return of Title IV Funds calculation on file. Cause ABC failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $28,431. Effect ABC has not complied with Title IV regulations that specify if a student withdraws from school within a certain time frame, a refund must be processed, calculated properly, and remitted to the Title IV program in accordance with established time frames. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-002. Recommendation I recommend that management immediately make the necessary determination as to whether the students unofficially withdrew from ABC, prepare the Return of Title IV Funds calculation, and return the funds to the Department of Education in a timely manner.

Audit Finding Reference Number Questioned Cost 2022 - 002 - Return of Title IV Funds $28,431 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. ABC is a college that is not required to take attendance. Thus, ABC must determine the student’s withdrawal date as either (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstances, (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Conditions and Contexts During my audit, I noted the following: • ABC did not return the required Title IV funds within the prescribed timeframe for two (2) students out of six (6) tested. The amount required to be returned totaled $2,846, was not returned; • The Return of Title IV Funds calculation was prepared incorrectly for two (2) out of six (6) students tested. The incorrect calculations resulted in $1,990 in funds to be returned by ABC; • Attendance rosters tested in which ABC was unable to document the last date of attendance or participation in any academic related activity for each of the students’ enrolled courses and received all non-passing grades for eleven (11) of the eleven (11) students selected for testing resulting in $23,595 to be returned by ABC; and • Sixteen (16) students from a listing of 69 (sixty-nine) students received Title IV aid and withdrew but did not have a Return of Title IV Funds calculation on file. Cause ABC failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $28,431. Effect ABC has not complied with Title IV regulations that specify if a student withdraws from school within a certain time frame, a refund must be processed, calculated properly, and remitted to the Title IV program in accordance with established time frames. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-002. Recommendation I recommend that management immediately make the necessary determination as to whether the students unofficially withdrew from ABC, prepare the Return of Title IV Funds calculation, and return the funds to the Department of Education in a timely manner.

Audit Finding Reference Number 2022 - 003 - Common Origination and Disbursement (COD) System Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Conditions and Contexts I noted the following conditions during my testing of the COD system: • The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for twenty-one (21) students out of sixty-three (63). The billing statements reported an excess of $36,383; • The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for twenty-nine (29) students out of seventy-one (71) tested. The billing statements reported a decrease in Direct loans of $1,437; and • The enrollment date was incorrectly reported in COD for ten (10) students out of sixty-three (63) tested. Cause ABC failed to adhere to established procedures in reporting to the COD system. Questioned Costs For purposes of this condition, I have no questioned costs. Effect ABC has not complied with Title IV regulations that require proper and accurate recording of the COD system. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-003. Recommendation I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.

Audit Finding Reference Number 2022 - 003 - Common Origination and Disbursement (COD) System Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Conditions and Contexts I noted the following conditions during my testing of the COD system: • The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for twenty-one (21) students out of sixty-three (63). The billing statements reported an excess of $36,383; • The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for twenty-nine (29) students out of seventy-one (71) tested. The billing statements reported a decrease in Direct loans of $1,437; and • The enrollment date was incorrectly reported in COD for ten (10) students out of sixty-three (63) tested. Cause ABC failed to adhere to established procedures in reporting to the COD system. Questioned Costs For purposes of this condition, I have no questioned costs. Effect ABC has not complied with Title IV regulations that require proper and accurate recording of the COD system. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-003. Recommendation I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.

Audit Finding Reference Number 2022 - 004 - Fiscal Operations Report and Application to Participant (FISAP) Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (3) indicates that ABC should submit its FISAP report containing critical information. The Compliance Supplement requires the auditor to examine financial reports to provide reasonable assurance that the reports of Federal awards submitted to the Federal awarding agency or pass-through entity include all activity of the reporting period, be supported by underlying accounting or performance records, and are fairly presented in accordance with program requirements. Conditions and Contexts During my audit of the FISAP report, I noted differences between the amounts recorded in the FISAP and supporting documentation. Cause A lack of adequate supervision over individuals preparing the FISAP report. Questioned Costs For the purpose of this finding, I have not questioned any costs. Effect ABC is not in compliance with federal reporting requirements. Repeat Finding No. Recommendation I recommend that ABC implement controls to ensure that information reported in the FISAP report is accurate and agrees to supporting documentation.

Audit Finding Reference Number 2022 - 004 - Fiscal Operations Report and Application to Participant (FISAP) Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (3) indicates that ABC should submit its FISAP report containing critical information. The Compliance Supplement requires the auditor to examine financial reports to provide reasonable assurance that the reports of Federal awards submitted to the Federal awarding agency or pass-through entity include all activity of the reporting period, be supported by underlying accounting or performance records, and are fairly presented in accordance with program requirements. Conditions and Contexts During my audit of the FISAP report, I noted differences between the amounts recorded in the FISAP and supporting documentation. Cause A lack of adequate supervision over individuals preparing the FISAP report. Questioned Costs For the purpose of this finding, I have not questioned any costs. Effect ABC is not in compliance with federal reporting requirements. Repeat Finding No. Recommendation I recommend that ABC implement controls to ensure that information reported in the FISAP report is accurate and agrees to supporting documentation.

Audit Finding Reference Number 2022 – 005 – Student Status Confirmation Report Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV Regulations, 34 CFR Section 682.610 (c) (i) (ii) (iii) stipulated that if a university discovers that a loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended, or a full-time student who has ceased to be enrolled on a full-time basis, ABC must notify the guarantee agency and/or the National Student Clearinghouse. Conditions and Contexts I noted during my audit twenty-five (25) students out of twenty-five (25) tested whose enrollment status was not reported or not reported correctly on the student status confirmation reports. Cause It appears that ABC did not properly report the student’s enrollment status to the guarantee agency and/or National Student Clearinghouse. Questioned Costs For purposes of this condition, I do not have any questioned costs. Effect Noncompliance with federal regulations. ABC did not properly report the student’s status to the guarantee agency and/or National Student Clearinghouse. Repeat Finding No. Recommendation I recommend that ABC determine the student’s proper enrollment status and report the accurate status to the guarantee agency and/or National Student Clearinghouse.

Audit Finding Reference Number Questioned Costs 2022 – 006 – Ineligible Aid Recipient $ 1,195 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations 34 CFR 668.32 (a)(2) stipulates that a student is eligible to receive Title IV Direct Loans if the student is enrolled at least half-time at an eligible institution. Conditions and Contexts I noted during my testing one (1) student out of nineteen (19) students tested who was not enrolled at least half-time and received Direct loans. Cause It appears that ABC did not property administer and disburse Title IV aid to eligible recipients. Questioned Costs For purposes of this condition, I have questioned costs totaling $1,195 related to the Direct loan program. Effect ABC disbursed financial aid to an ineligible student. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-006. Recommendation I recommend that management of ABC adhere to established procedures to ensure that all federal funds are disbursed to eligible students.

Audit Finding Reference Number 2022 – 007 – School Account Statements (SAS) Reports Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5, Student Financial Assistance Programs, Section III, Part N – Special Test and Provisions, Number 7, Direct Loan Reconciliation stipulated that ABC must reconcile monthly the School Account Statement (SAS) data file to ABC’s financial records. Conditions and Contexts During my audit of the SAS reports, I noted ABC either did not provide support for the SAS reports or provided conflicting information between the College’s financial records, drawdown reports, and the common origination disbursements system. Cause A lack of adequate record keeping by the appropriate personnel. Questioned Costs For the purpose of this finding, I have not questioned costs. Effect ABC is not in compliance with federal record keeping requirements for the reporting. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-007. Recommendation I recommend that ABC implement procedures to ensure required reports are prepared as prescribed.

Audit Finding Reference Number 2022 – 007 – School Account Statements (SAS) Reports Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5, Student Financial Assistance Programs, Section III, Part N – Special Test and Provisions, Number 7, Direct Loan Reconciliation stipulated that ABC must reconcile monthly the School Account Statement (SAS) data file to ABC’s financial records. Conditions and Contexts During my audit of the SAS reports, I noted ABC either did not provide support for the SAS reports or provided conflicting information between the College’s financial records, drawdown reports, and the common origination disbursements system. Cause A lack of adequate record keeping by the appropriate personnel. Questioned Costs For the purpose of this finding, I have not questioned costs. Effect ABC is not in compliance with federal record keeping requirements for the reporting. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-007. Recommendation I recommend that ABC implement procedures to ensure required reports are prepared as prescribed.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 009 – Pell Grant Annual and Lifetime Eligibility $15,822 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations, 34 CFR Section 690.62 (a) stipulates that the amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each year. Each student’s Pell grant is based upon their enrollment status, cost of attendance and expected family contribution. The Student Financial Aid Handbook, Section E, Eligibility, indicates students that receive Pell may not receive more than six (6) scheduled awards (twelve (12) semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU). The LEU maximum percentage for student eligibility is six hundred percent (600%). Conditions and Contexts During my audit I noted the following: • six (6) students out of fifty-five (55) tested whose Pell grant amount was calculated incorrectly. This resulted in ABC under-disbursing Pell in the amount of $15,822; and • one (1) student out of five (5) tested who was flagged by the Department of Education for possibly exceeding their Lifetime Eligibility Usage of 600%. It was determined the student had not exceeded their LEU. However, ABC reduced the amount of Pell disbursed for the 2021-2022 academic year. It was determined the student had not exceeded Lifetime Eligibility Usage of 600% and could receive the full amount of Pell of $6,495 instead of the $1,624 disbursed. This resulted in ABC under-disbursing Pell in the amount of $4,871. This amount is included in bullet 1 above. Cause It appears that ABC did not review and verify all components of the Pell grant calculation to ensure the proper amount of Pell was disbursed. Questioned Costs For purposes of this condition, I have questioned costs totaling $15,822. Effect ABC disbursed excess Pell grant funds to students. Repeat Finding No. Recommendation I recommend that ABC adhere to federal prescribed regulations by calculating and disbursing Pell grants in accordance with the Department of Education’s Pell payment schedule and in accordance with the Lifetime Eligibility Usage limits.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number Questioned Cost 2022 - 002 - Return of Title IV Funds $28,431 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. ABC is a college that is not required to take attendance. Thus, ABC must determine the student’s withdrawal date as either (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstances, (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Conditions and Contexts During my audit, I noted the following: • ABC did not return the required Title IV funds within the prescribed timeframe for two (2) students out of six (6) tested. The amount required to be returned totaled $2,846, was not returned; • The Return of Title IV Funds calculation was prepared incorrectly for two (2) out of six (6) students tested. The incorrect calculations resulted in $1,990 in funds to be returned by ABC; • Attendance rosters tested in which ABC was unable to document the last date of attendance or participation in any academic related activity for each of the students’ enrolled courses and received all non-passing grades for eleven (11) of the eleven (11) students selected for testing resulting in $23,595 to be returned by ABC; and • Sixteen (16) students from a listing of 69 (sixty-nine) students received Title IV aid and withdrew but did not have a Return of Title IV Funds calculation on file. Cause ABC failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $28,431. Effect ABC has not complied with Title IV regulations that specify if a student withdraws from school within a certain time frame, a refund must be processed, calculated properly, and remitted to the Title IV program in accordance with established time frames. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-002. Recommendation I recommend that management immediately make the necessary determination as to whether the students unofficially withdrew from ABC, prepare the Return of Title IV Funds calculation, and return the funds to the Department of Education in a timely manner.

Audit Finding Reference Number Questioned Cost 2022 - 002 - Return of Title IV Funds $28,431 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 Section (N) (3) specifies that when a student receives Title IV assistance and withdraws from an institution, the institution must determine the amount of Title IV aid earned by the student as of the withdrawal date. The difference between any amounts earned that is less than the amount disbursed must be returned to the Title IV program within the prescribed time frame. ABC is a college that is not required to take attendance. Thus, ABC must determine the student’s withdrawal date as either (1) the date, as determined by the institution, that the student began the withdrawal process prescribed by the institution; (2) the date, as determined by the institution, that the student otherwise provided official notification to the institution, in writing or orally, of his or her intent to withdraw; (3) if the student ceases attendance without providing official notification to the institution of his or her withdrawal, the midpoint of the payment period or, if applicable, the period of enrollment; (4) if the institution determines that a student did not begin the withdrawal process or otherwise notify the institution of the intent to withdraw due to illness, accident, grievous personal loss or other circumstances beyond the student’s control, the date the institution determines is related to that circumstances, (5) if a student does not return from an approved leave of absence, the date that the institution determines the student began the leave of absence; or (6) if the student takes an unapproved leave of absence, the date that the student began the leave of absence. Conditions and Contexts During my audit, I noted the following: • ABC did not return the required Title IV funds within the prescribed timeframe for two (2) students out of six (6) tested. The amount required to be returned totaled $2,846, was not returned; • The Return of Title IV Funds calculation was prepared incorrectly for two (2) out of six (6) students tested. The incorrect calculations resulted in $1,990 in funds to be returned by ABC; • Attendance rosters tested in which ABC was unable to document the last date of attendance or participation in any academic related activity for each of the students’ enrolled courses and received all non-passing grades for eleven (11) of the eleven (11) students selected for testing resulting in $23,595 to be returned by ABC; and • Sixteen (16) students from a listing of 69 (sixty-nine) students received Title IV aid and withdrew but did not have a Return of Title IV Funds calculation on file. Cause ABC failed to adhere to established procedures in processing certain refunds. Questioned Costs For purposes of this condition, I have questioned costs totaling $28,431. Effect ABC has not complied with Title IV regulations that specify if a student withdraws from school within a certain time frame, a refund must be processed, calculated properly, and remitted to the Title IV program in accordance with established time frames. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-002. Recommendation I recommend that management immediately make the necessary determination as to whether the students unofficially withdrew from ABC, prepare the Return of Title IV Funds calculation, and return the funds to the Department of Education in a timely manner.

Audit Finding Reference Number 2022 - 003 - Common Origination and Disbursement (COD) System Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Conditions and Contexts I noted the following conditions during my testing of the COD system: • The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for twenty-one (21) students out of sixty-three (63). The billing statements reported an excess of $36,383; • The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for twenty-nine (29) students out of seventy-one (71) tested. The billing statements reported a decrease in Direct loans of $1,437; and • The enrollment date was incorrectly reported in COD for ten (10) students out of sixty-three (63) tested. Cause ABC failed to adhere to established procedures in reporting to the COD system. Questioned Costs For purposes of this condition, I have no questioned costs. Effect ABC has not complied with Title IV regulations that require proper and accurate recording of the COD system. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-003. Recommendation I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.

Audit Finding Reference Number 2022 - 003 - Common Origination and Disbursement (COD) System Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.268 Federal Direct Student Loan (Direct) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (1) Financial Reporting, indicates that schools submit PELL origination records and disbursement records to the COD system. Key items on the origination records are social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance, and academic calendar. Institutions must report student payment data within 30 calendar days after the school makes a payment; or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Conditions and Contexts I noted the following conditions during my testing of the COD system: • The PELL amount was disbursed in the COD system did not agree to the students’ billing statements for twenty-one (21) students out of sixty-three (63). The billing statements reported an excess of $36,383; • The Direct loan amounts disbursed in the COD system did not agree to the students’ billing statements for twenty-nine (29) students out of seventy-one (71) tested. The billing statements reported a decrease in Direct loans of $1,437; and • The enrollment date was incorrectly reported in COD for ten (10) students out of sixty-three (63) tested. Cause ABC failed to adhere to established procedures in reporting to the COD system. Questioned Costs For purposes of this condition, I have no questioned costs. Effect ABC has not complied with Title IV regulations that require proper and accurate recording of the COD system. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-003. Recommendation I recommend that ABC implements controls to ensure that information reported to the COD system is accurate.

Audit Finding Reference Number 2022 - 004 - Fiscal Operations Report and Application to Participant (FISAP) Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (3) indicates that ABC should submit its FISAP report containing critical information. The Compliance Supplement requires the auditor to examine financial reports to provide reasonable assurance that the reports of Federal awards submitted to the Federal awarding agency or pass-through entity include all activity of the reporting period, be supported by underlying accounting or performance records, and are fairly presented in accordance with program requirements. Conditions and Contexts During my audit of the FISAP report, I noted differences between the amounts recorded in the FISAP and supporting documentation. Cause A lack of adequate supervision over individuals preparing the FISAP report. Questioned Costs For the purpose of this finding, I have not questioned any costs. Effect ABC is not in compliance with federal reporting requirements. Repeat Finding No. Recommendation I recommend that ABC implement controls to ensure that information reported in the FISAP report is accurate and agrees to supporting documentation.

Audit Finding Reference Number 2022 - 004 - Fiscal Operations Report and Application to Participant (FISAP) Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal Pell Grant Program (PELL) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) Federal Award Year June 30, 2022 Federal Agencies U. S. Department of Education Pass-Through Entity Not applicable Criteria OMB 2 CFR 200, Subpart F Compliance Supplement, Part 5 - Student Financial Assistance Programs, Section (L) (3) indicates that ABC should submit its FISAP report containing critical information. The Compliance Supplement requires the auditor to examine financial reports to provide reasonable assurance that the reports of Federal awards submitted to the Federal awarding agency or pass-through entity include all activity of the reporting period, be supported by underlying accounting or performance records, and are fairly presented in accordance with program requirements. Conditions and Contexts During my audit of the FISAP report, I noted differences between the amounts recorded in the FISAP and supporting documentation. Cause A lack of adequate supervision over individuals preparing the FISAP report. Questioned Costs For the purpose of this finding, I have not questioned any costs. Effect ABC is not in compliance with federal reporting requirements. Repeat Finding No. Recommendation I recommend that ABC implement controls to ensure that information reported in the FISAP report is accurate and agrees to supporting documentation.

Audit Finding Reference Number 2022 – 005 – Student Status Confirmation Report Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV Regulations, 34 CFR Section 682.610 (c) (i) (ii) (iii) stipulated that if a university discovers that a loan has been made to or on behalf of a student who enrolled at that school, but who has ceased to be enrolled on at least a half-time basis; a student who has been accepted for enrollment at that school, but who failed to enroll on at least a half-time basis for the period for which the loan was intended, or a full-time student who has ceased to be enrolled on a full-time basis, ABC must notify the guarantee agency and/or the National Student Clearinghouse. Conditions and Contexts I noted during my audit twenty-five (25) students out of twenty-five (25) tested whose enrollment status was not reported or not reported correctly on the student status confirmation reports. Cause It appears that ABC did not properly report the student’s enrollment status to the guarantee agency and/or National Student Clearinghouse. Questioned Costs For purposes of this condition, I do not have any questioned costs. Effect Noncompliance with federal regulations. ABC did not properly report the student’s status to the guarantee agency and/or National Student Clearinghouse. Repeat Finding No. Recommendation I recommend that ABC determine the student’s proper enrollment status and report the accurate status to the guarantee agency and/or National Student Clearinghouse.

Audit Finding Reference Number Questioned Costs 2022 – 006 – Ineligible Aid Recipient $ 1,195 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations 34 CFR 668.32 (a)(2) stipulates that a student is eligible to receive Title IV Direct Loans if the student is enrolled at least half-time at an eligible institution. Conditions and Contexts I noted during my testing one (1) student out of nineteen (19) students tested who was not enrolled at least half-time and received Direct loans. Cause It appears that ABC did not property administer and disburse Title IV aid to eligible recipients. Questioned Costs For purposes of this condition, I have questioned costs totaling $1,195 related to the Direct loan program. Effect ABC disbursed financial aid to an ineligible student. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-006. Recommendation I recommend that management of ABC adhere to established procedures to ensure that all federal funds are disbursed to eligible students.

Audit Finding Reference Number 2022 – 007 – School Account Statements (SAS) Reports Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5, Student Financial Assistance Programs, Section III, Part N – Special Test and Provisions, Number 7, Direct Loan Reconciliation stipulated that ABC must reconcile monthly the School Account Statement (SAS) data file to ABC’s financial records. Conditions and Contexts During my audit of the SAS reports, I noted ABC either did not provide support for the SAS reports or provided conflicting information between the College’s financial records, drawdown reports, and the common origination disbursements system. Cause A lack of adequate record keeping by the appropriate personnel. Questioned Costs For the purpose of this finding, I have not questioned costs. Effect ABC is not in compliance with federal record keeping requirements for the reporting. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-007. Recommendation I recommend that ABC implement procedures to ensure required reports are prepared as prescribed.

Audit Finding Reference Number 2022 – 007 – School Account Statements (SAS) Reports Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5, Student Financial Assistance Programs, Section III, Part N – Special Test and Provisions, Number 7, Direct Loan Reconciliation stipulated that ABC must reconcile monthly the School Account Statement (SAS) data file to ABC’s financial records. Conditions and Contexts During my audit of the SAS reports, I noted ABC either did not provide support for the SAS reports or provided conflicting information between the College’s financial records, drawdown reports, and the common origination disbursements system. Cause A lack of adequate record keeping by the appropriate personnel. Questioned Costs For the purpose of this finding, I have not questioned costs. Effect ABC is not in compliance with federal record keeping requirements for the reporting. Repeat Finding Yes. See Schedule of Prior Year Audit Finding 2021-007. Recommendation I recommend that ABC implement procedures to ensure required reports are prepared as prescribed.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 008 – Aid in Excess of Documented Need $47,586 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) 84.268 Federal Direct Student Loans (Direct) 84.007 Federal Supplemental Educational Opportunity Grant (FSEOG) 84.033 Federal Work-Study (FWS) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Uniform Guidance Compliance Supplement, Part 5 Section E (Eligibility) specified that the annual award should be calculated based upon certain factors and coordinated among all programs to ensure that the total aid is not awarded in excess of the student’s financial need. Title IV regulations, Section(s) 673.5, 682.603, and 685.301 state that an institution may not award financial aid to a student if the aid, when combined with other resources, exceeds the student’s financial need. Conditions and Contexts During my audit I noted eleven (11) students out of seventy-one (71) tested received financial aid in excess of their documented need. Cause It appears that ABC did not properly monitor the awarding and disbursing of financial aid to certain students. Questioned Costs For purposes of this condition, I have questioned costs totaling $47,586 relating to the Direct loan program. Effect The failure of ABC to consider all available resources resulted in the over awarding of financial aid. Repeat Finding No. Recommendation I recommend that ABC adhere to established procedures and ensure that the total financial aid received by students does not exceed their documented need.

Audit Finding Reference Number Questioned Cost 2022 – 009 – Pell Grant Annual and Lifetime Eligibility $15,822 Federal Program and Specific Federal Award Identification CFDA Title and Number 84.063 Federal PELL Grant Program (PELL) Federal Award Number June 30, 2022 Federal Agencies U.S. Department of Education Pass-Through Entity Not applicable Criteria Title IV regulations, 34 CFR Section 690.62 (a) stipulates that the amount of a student’s Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each year. Each student’s Pell grant is based upon their enrollment status, cost of attendance and expected family contribution. The Student Financial Aid Handbook, Section E, Eligibility, indicates students that receive Pell may not receive more than six (6) scheduled awards (twelve (12) semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU). The LEU maximum percentage for student eligibility is six hundred percent (600%). Conditions and Contexts During my audit I noted the following: • six (6) students out of fifty-five (55) tested whose Pell grant amount was calculated incorrectly. This resulted in ABC under-disbursing Pell in the amount of $15,822; and • one (1) student out of five (5) tested who was flagged by the Department of Education for possibly exceeding their Lifetime Eligibility Usage of 600%. It was determined the student had not exceeded their LEU. However, ABC reduced the amount of Pell disbursed for the 2021-2022 academic year. It was determined the student had not exceeded Lifetime Eligibility Usage of 600% and could receive the full amount of Pell of $6,495 instead of the $1,624 disbursed. This resulted in ABC under-disbursing Pell in the amount of $4,871. This amount is included in bullet 1 above. Cause It appears that ABC did not review and verify all components of the Pell grant calculation to ensure the proper amount of Pell was disbursed. Questioned Costs For purposes of this condition, I have questioned costs totaling $15,822. Effect ABC disbursed excess Pell grant funds to students. Repeat Finding No. Recommendation I recommend that ABC adhere to federal prescribed regulations by calculating and disbursing Pell grants in accordance with the Department of Education’s Pell payment schedule and in accordance with the Lifetime Eligibility Usage limits.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.

Audit Finding Reference Number 2022 – 010 – Late Submission of Audit Report Criteria Pursuant to the requirement of Uniform Guidance 2 CFR Part 200.512(a), Single audits are required to be completed and the data collection form and reporting package submitted within the earlier of thirty (30) days after receipt of the auditor’s report, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal Holiday, the reporting package is due the next business day. Conditions and Contexts The June 30, 2022 audit report was not submitted within the prescribed time frame. Required by federal regulations. The audit report was outstanding nine (9) months after the entity’s fiscal year. Cause Management failed to ensure the audit report was issued within the prescribed time frame. Questioned Costs For purposes of this condition, I have no questioned cost. Effect ABC. has not complied with the audit requirement of Uniform Guidance 2 CFR Part 200.512(a). Repeat Finding No. Recommendation I recommend that management of ABC take steps to ensure that the Single Audit is submitted within the prescribed deadlines.