Audit 311103

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 1 student, out of a sample of 22, that was not refunded credit balances within the required timeframe by 14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-009 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 690.80(b) Recalculation of a Federal Pell Grant award: (b) Change in enrollment status. (1) If the student's enrollment status changes from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. (2) (i) If the student's projected enrollment status changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students. (ii) If a student's projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance. Condition The Federal Government requires Pell Grant awards to be recalculated when a student fails to begin attendance in each of their scheduled courses which causes a change in the student’s enrollment status. During our testing, we noted 1 student, out of a sample of 40, whose Pell Grant award was not recalculated after their enrollment status changed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to identify the change in the student’s enrollment status for recalculation of Pell award. As a result, the College did not properly recalculate the student’s Pell Grant award. Effect The College over-awarded Pell Grant funds. Questioned Costs $863 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should update their procedures for identifying status changes due to student’s failure to begin attendance in all scheduled courses. These procedures should include a timeline for reporting students who fail to begin attendance by faculty that will allow for the timely recalculation of Pell Grant awards. The importance of accurate and timely reporting of attendance should be emphasized to the faculty. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2022-2023 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-004 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2022-2023 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-004 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-005 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 87, Number 105): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 139 days. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable.   Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-007 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-007 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 2, that had unclaimed funds exceeding the federal day limit by 40 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check totaling $2,234, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2022-006 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 2, that had unclaimed funds exceeding the federal day limit by 40 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check totaling $2,234, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2022-006 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. Based on discussion with the College, we noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-008 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.22(f)(2): (i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include - (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time. Condition The Federal Government requires that when the student withdraws from all classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. During our testing, we noted 1 student, out of a sample of 3, where the incorrect number of total days in the Spring semester were used to calculate the student’s percentage of Title IV earned. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In this instance, the College incorrectly calculated the enrollment period as student’s last day of attendance was excluded form calculation, which resulted in rounding variance. Effect The College calculated the Return to Title IV (“R2T4”) forms incorrectly and returned an insufficient amount of Title IV funds to the Department of Education. Questioned Costs $33.25 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should review their current policies and procedures regarding formal review process of the Return of Title IV calculations by an individual separate from preparer of Return of Title IV calculation to ensure that return of Title IV funds is properly calculated. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 685.304(b): (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the Title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 5 students, out of a sample of 40, did not have evidence that exit counseling was performed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not Applicable Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Criteria According to 2 CFR 200.403 Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition The Federal Government requires that costs must be adequately documented and must be incurred during the approved budget period. During our testing, we noted the College failed to provide a copy of check or ACH payment information for 1 expenditure, out of a sample of 5. As a result, the College was unable to provide the proof of payment to support the expenditure is an allowable cost. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to keep the proof of payment to support the expenditure that was reimbursed from the federal award. Effect The invoice that was reimbursed from the federal award may not be an allowable cost. Questioned Costs $1,655 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to verify that reimbursement requests are only submitted for invoices that have been paid. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(h): Title IV, Higher Education Act (“HEA”) credit balances. (1) A Title IV, HEA credit balance occurs whenever the amount of Title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. (2) A Title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than - (i) No later than 14 days after the balance occurred if the balance occurred after the first day of class of a payment period; or (ii) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of that payment period. Condition The Federal Government requires that whenever Title IV aid is disbursed on a student’s account, the account must be reviewed to determine if the disbursement caused a credit balance. If the credit balance was caused by Title IV funds, the College must refund the balance directly to the student within 14 days of the disbursement of funds. During our testing, we noted 1 student, out of a sample of 22, that was not refunded credit balances within the required timeframe by 14 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not implement appropriate internal controls related to disbursements over student's accounts to ensure that refunds were processed for credit balances within the required timeframe. Effect The College did not refund Title IV credit balances within the required 14-day time frame and therefore was not in compliance with federal requirements. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-009 included in the summary schedule of prior year findings. Recommendation The Business Office should continue to develop their procedures to identify credit balances caused by changes on students’ accounts as well as disbursements. This includes reviewing accounts after late disbursement of Title IV aid as well as tuition and fee adjustments, health insurance waivers and bookstore credits. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 690.80(b) Recalculation of a Federal Pell Grant award: (b) Change in enrollment status. (1) If the student's enrollment status changes from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. (2) (i) If the student's projected enrollment status changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students. (ii) If a student's projected enrollment status changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance. Condition The Federal Government requires Pell Grant awards to be recalculated when a student fails to begin attendance in each of their scheduled courses which causes a change in the student’s enrollment status. During our testing, we noted 1 student, out of a sample of 40, whose Pell Grant award was not recalculated after their enrollment status changed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to identify the change in the student’s enrollment status for recalculation of Pell award. As a result, the College did not properly recalculate the student’s Pell Grant award. Effect The College over-awarded Pell Grant funds. Questioned Costs $863 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should update their procedures for identifying status changes due to student’s failure to begin attendance in all scheduled courses. These procedures should include a timeline for reporting students who fail to begin attendance by faculty that will allow for the timely recalculation of Pell Grant awards. The importance of accurate and timely reporting of attendance should be emphasized to the faculty. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2022-2023 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-004 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 and 84.268 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change in the amount of a grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to Common Origination and Disbursement (“COD”) 2022-2023 Technical Reference: Disbursement Date is the date the money was credited to the student’s account or paid to the student (or borrower, if PLUS loan) directly for a specific disbursement number. Disbursement Date is not the date of the adjustment transaction. The Disbursement Date is submitted on a Disbursement transaction as well as on an Adjusted Disbursement Amount transaction. Condition Federal regulations require the College to report the Federal Government’s COD Federal Pell Grant and Direct Loan disbursements made to students. During our testing, we noted for 6 students, out of a sample of 40, in which the disbursed date in the student account did not align with the disbursed date in the COD. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate internal controls in place to validate that the disbursement date per the student's account statement matched the disbursement date reported to COD. Effect The College did not report the correct disbursement date to the COD. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-004 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure that COD disbursement information matches the College's records. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-005 Federal agency: U.S. Department of Education Programs: Federal Pell Grants Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Cash Management and Reporting Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 87, Number 105): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), Title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted 1 student, out of a sample of 40, was not reported within the required timeframe by 139 days. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days, however, in this case the procedures were not completed properly. Effect The College did not report Pell Grant disbursements to COD within the required time frame. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable Not applicable.   Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-007 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-006 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.309(b)(2): Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that - (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated April 2022: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (“NSLDS”). An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus record and the Program Record, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Condition The Federal Government requires the College to report student enrollment changes to the NSLDS within 60 days. During our testing, 2 out of 10 students were reported late to the NSLDS by 35 to 96 days and 4 out of 10 students reported an incorrect effective date to the NSLDS. Additionally, 1 out of 10 students had an incorrect status change reported to the NSLDS. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to ensure enrollment status changes were being reported to the NSLDS timely and accurately. Effect Late or incorrect effective dates may impact the students’ loan grace periods. Questioned Costs Not applicable. Identification as a Repeat Finding, if applicable See finding 2022-007 included in the summary schedule of prior year findings. Recommendation The College should strengthen their internal controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 2, that had unclaimed funds exceeding the federal day limit by 40 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check totaling $2,234, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2022-006 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (“HEA”) program funds, except Federal Work Study (“FWS”) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 2, that had unclaimed funds exceeding the federal day limit by 40 days. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have appropriate internal controls in place to monitor the outstanding check aging to ensure that the 240-day timeframe was not exceeded. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was one outstanding check totaling $2,234, which pertained specifically to federal-sourced funds. Identification as a Repeat Finding, if applicable See finding 2022-006 included in the summary schedule of prior year findings. Recommendation The College should examine its policies and procedures and implement effective internal controls related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 685.300(b): In the program participation agreement, the school must promise to comply with the Act and applicable regulations and must agree to - (5) On a monthly basis, reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary; An electronic announcement dated December 18, 2020, described the process by which the Department of Education defines Direct Loan Reconciliation. Direct reconciliation is the process by which Direct Loan funds received and disbursed as recorded on the Department of Education’s systems are reviewed and compared with a school’s internal records and discrepancies are identified and resolved. Condition Federal regulations require the College to reconcile their institutional records with their COD disbursement records monthly. This reconciliation includes identifying discrepancies and resolving them in a timely manner. Based on discussion with the College, we noted that the College relied on the third-party servicer to perform monthly reconciliation but did not review the reconciliation to resolve any discrepancies. Cause The College did not implement appropriate internal controls over monthly reconciliation completed by the third-party servicer to ensure that differences found in reconciliations between institutional records and COD's disbursement records were resolved in a timely basis. Effect Discrepancies are not identified and resolved in a timely manner. Questioned Costs Not applicable Identification as a Repeat Finding, if applicable See finding 2022-008 included in the summary schedule of prior year findings. Recommendation The College should implement internal controls to validate that reconciliations are performed monthly between the College's institutional records and disbursement records submitted to the COD and any discrepancies are identified and resolved in a timely manner. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-009 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 Award year: 2023 Compliance requirement: Special Tests Criteria According to 34 CFR 668.22(f)(2): (i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include - (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time. Condition The Federal Government requires that when the student withdraws from all classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. During our testing, we noted 1 student, out of a sample of 3, where the incorrect number of total days in the Spring semester were used to calculate the student’s percentage of Title IV earned. Our sample was not, and was not intended to be, statistically valid. Cause The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In this instance, the College incorrectly calculated the enrollment period as student’s last day of attendance was excluded form calculation, which resulted in rounding variance. Effect The College calculated the Return to Title IV (“R2T4”) forms incorrectly and returned an insufficient amount of Title IV funds to the Department of Education. Questioned Costs $33.25 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should review their current policies and procedures regarding formal review process of the Return of Title IV calculations by an individual separate from preparer of Return of Title IV calculation to ensure that return of Title IV funds is properly calculated. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-010 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 685.304(b): (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the Title IV programs is reasonably available shortly after the counseling to answer the student borrower's questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study-abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program. (3) If a student borrower withdraws from school without the school's prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower's last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition The Federal Government requires that when the student ceases at least half-time study, withdraws from all classes or graduates, the college must provide exit counseling to students within 30 days. During our testing, we noted 5 students, out of a sample of 40, did not have evidence that exit counseling was performed. Our sample was not, and was not intended to be, statistically valid. Cause The College did not have adequate controls in place to ensure that exit counseling was conducted with Direct Loans borrowers following changes in enrollment which require administration of exit counseling for Direct Loans. Effect The College did not meet federal requirements and students did not complete exit counseling following graduation, cease of enrollment. Questioned Costs Not Applicable Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to ensure exit counseling is completed for a student when student ceases enrollment at least half-time, withdraws, or graduates from the College. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance listing #: 84.063 & 84.268 Award year: 2023 Compliance requirement: Eligibility Criteria According to 34 CFR 668.32: A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of this section or meets the requirement in paragraph (n) of this section as follows: (e) (1) Has a high school diploma or its recognized equivalent Condition The Federal Government requires that evidence of a high school diploma, its recognized equivalent, or an alternative educational requirement be provided by the student prior to their first disbursement. During our testing, we noted the College failed to retain a high school diploma or recognized equivalent for 2 students, out of a sample of 40. As a result, the College was unable to provide the necessary documentation to support the students’ eligibility. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to validate that students are eligible to receive Title IV prior to their first disbursement. Effect The students were awarded and disbursed federal student aid that they may not be eligible to receive. Questioned Costs $29,187 Identification as a Repeat Finding, if applicable See finding 2022-003 included in the summary schedule of prior year findings. Recommendation The College should implement internal control procedures to ensure all students are eligible to receive federal student aid before their first disbursement. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-012 Federal agency: U.S. Department of Treasury Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance listing #: 21.027 Award year: 2023 Compliance requirement: Allowable Costs Criteria According to 2 CFR 200.403 Factors affecting allowability of costs: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition The Federal Government requires that costs must be adequately documented and must be incurred during the approved budget period. During our testing, we noted the College failed to provide a copy of check or ACH payment information for 1 expenditure, out of a sample of 5. As a result, the College was unable to provide the proof of payment to support the expenditure is an allowable cost. Our sample was not, and was not intended to be, statistically valid. Cause The College failed to have the proper internal controls in place to keep the proof of payment to support the expenditure that was reimbursed from the federal award. Effect The invoice that was reimbursed from the federal award may not be an allowable cost. Questioned Costs $1,655 Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should implement internal control procedures to verify that reimbursement requests are only submitted for invoices that have been paid. View of Responsible Officials The College agrees with the finding.