Audit 309212

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program, 84.063 - Federal Pell Grant Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: The University is subject to compliance requirements pertaining to the disbursement of funds to students under Federal Student Aid (FSA) programs within the Student Financial Assistance cluster. For any students participating in electronic transactions, schools must obtain their voluntary consent to participate pursuant to The Electronic Signatures in Global and National Commerce Act (or the E-Sign Act). Condition: While reviewing the underlying support for a sample of 25 students, we noted that voluntary consent for electronic disbursement participation was not obtained for any of these students. Questioned Costs: None Cause: The University inadvertently omitted the process where the student would voluntarily consent to participate in electronic transactions from the list of terms and conditions each student is required to accept. Effect: A lack of student consent to participate in electronic transactions may result in the transactions being denied legal effect, validity, or enforceability solely because it is in electronic form or because an electronic signature or electronic record was used in its formation. Recommendation: We recommend that management review the requirements of the E-Sign Act with respect to student electronic transaction voluntary consents and put in place processes that will ensure such consent is captured in future transactions. The University should continually assess the operation of the updated policies and procedures in place as it relates to voluntary consent. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: In accordance with 34 CFR 690.83(b)(2) and 685.309, schools are required to report the enrollment status of students who received Federal Pell Grants and/or Federal Direct Loans to the National Student Loan Data System (“NSLDS”). Enrollment information, inclusive of campus level and program level data, must be reviewed, updated and validated by the institution in a timely manner as it is used to determine the borrower’s eligibility for in-school status, deferment, interest subsidy and grace period. Specific to the Federal Direct Loan program, enrollment changes, such as a change from full-time to half-time status, graduation, withdrawal, or an approved leave of absence, are changes that need to be reported within 60 days of the change. Condition: We reviewed a sample of 25 students enrolled at the University who received either Federal Pell Grants and/or Federal Direct Loans and had a change in enrollment between March 1, 2023 through September 30, 2023 of the fiscal year. Through our enrollment reporting testing, we identified seven students that were reported greater than 60 days after the effective date of the change in enrollment status in the NSLDS (64 days for four selections (3 to half-time status; 1 to less than half-time status), 191 days for one graduate selection, and 282 days for two graduate selections). Questioned Costs: None Cause: Although the University has processes and controls to timely report student enrollment changes to the National Student Clearinghouse (“NSC”) and to the NSLDS, these controls did not operate as designed during the period to meet the 60-day reporting requirement. Specifically for the three graduate selections, the University did not timely review the unapplied records reported by NSC for the University’s review so that records could be reported to NSLDS. For the four non-graduate selections, the University did not submit the enrollment reporting changes to NSC in a timely manner to allow for the enrollment change records to be submitted to NSLDS within the requisite 60 days of the effective date of the change. Effect: The effective administration of Federal Pell Grants and Federal Direct Loans could be impacted when changes in students’ enrollment are not reported timely. The accuracy and timeliness of reporting enrollment information is important, as a student’s enrollment status determines eligibility for in-school status, deferment, grace period and repayments, as well as the government’s payment of interest subsidies. Recommendation: We recommend the University enhance its controls and revise its procedures to ensure that not only are status changes reported to the NSC, but also that the enrollment changes are reported appropriately and timely from the NSC to the NSLDS. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.

Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Name: Not applicable Award Identifying Number: Not applicable Award Year: Fiscal year 2023 Pass-through Entity: Not applicable Criteria: Schools are required to confirm and report origination and disbursement records to the U.S. Department of Education Common Origination and Disbursement (“COD”) system (OMB No. 1845-0039). Key information included on the origination records, if applicable, include the social security number, award amount, enrollment date, verification status code, transaction number, cost of attendance and the “Academic Start Date” and “Academic End Date” of students who receive Federal Pell Grants and/or Federal Direct Loans. This information should agree to the students’ records maintained by the University. Condition: We reviewed a sample of 25 students that received Federal Pell Grants and/or Federal Direct Loans during the fiscal year. Through our reporting testing, we identified one student within the Law School that received a Federal Direct-Unsubsidized Loan where the Academic End Date of 5/20/2023 in the COD system did not agree to the student’s records, noting an Academic End Date of 5/10/2023. Questioned Costs: None Cause: The University noted that the Academic End Dates for all students that received Federal Direct Loans during the fiscal year and were enrolled in the Law School were incorrectly reported. The University inadvertently applied the incorrect academic calendar for these students. This error occurred during a time of staffing turnover due to COVID at the time these academic calendars were set. Although the University has processes and controls to accurately report Academic Start and End Dates in the COD system, these controls did not operate as designed during the period to meet the reporting requirement. Effect: Reporting accurate information in the COD system is necessary to determine eligibility and accrued interest, if applicable, on student financial assistance Title IV programs. Recommendation: We recommend the University enhance its training policies and procedures for preparers and reviewers, specifically re-emphasizing the reporting requirements and separate Law School academic calendars, to help ensure that accurate reporting is included in the COD system for all fields, including the Academic End Date. View of Responsible Officials: Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings.