Audit 318688

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 9, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 45 to 90 days. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 2 students, or 22.2% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(e): (1) General. The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. (4) Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Department is responsible for completing the Return of Title IV calculation to determine how much Title IV funds the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, Franklin Cummings Tech is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). During our testing, we noted 2 students, out of a sample of 9, where a return of unearned Title IV funds was not calculated even though the students withdrew and 1 out of 9 students received additional Title IV funds after a return of Title IV funds was processed. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be calculated and to return unearned portions to the Department of Education. Effect Franklin Cummings Tech did not return unearned Title IV funds. Questioned Costs $9,939 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 3 students, or 33.3% of our sample, were not calculated and processed correctly for return of unearned Title IV funds. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the process of Return of Title IV calculations for all students who withdraw to ensure that funds earned are calculated correctly and unearned portions are returned to the Department of Education properly. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 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 June 2019: 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”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 2 out of 27 students were reported late to the NSLDS by 98 days. During our testing, 1 out of 27 students reported an incorrect effective date, and 4 out of 27 students had an incorrect status reported to the NSLDS. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates and status to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 27 students selected for testing, 4 students, or 14.8% of our sample, did not report the correct effective dates and status to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 9, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 45 to 90 days. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 2 students, or 22.2% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(e): (1) General. The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. (4) Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Department is responsible for completing the Return of Title IV calculation to determine how much Title IV funds the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, Franklin Cummings Tech is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). During our testing, we noted 2 students, out of a sample of 9, where a return of unearned Title IV funds was not calculated even though the students withdrew and 1 out of 9 students received additional Title IV funds after a return of Title IV funds was processed. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be calculated and to return unearned portions to the Department of Education. Effect Franklin Cummings Tech did not return unearned Title IV funds. Questioned Costs $9,939 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 3 students, or 33.3% of our sample, were not calculated and processed correctly for return of unearned Title IV funds. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the process of Return of Title IV calculations for all students who withdraw to ensure that funds earned are calculated correctly and unearned portions are returned to the Department of Education properly. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 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 June 2019: 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”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 2 out of 27 students were reported late to the NSLDS by 98 days. During our testing, 1 out of 27 students reported an incorrect effective date, and 4 out of 27 students had an incorrect status reported to the NSLDS. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates and status to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 27 students selected for testing, 4 students, or 14.8% of our sample, did not report the correct effective dates and status to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 9, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 45 to 90 days. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 2 students, or 22.2% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(e): (1) General. The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. (4) Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Department is responsible for completing the Return of Title IV calculation to determine how much Title IV funds the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, Franklin Cummings Tech is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). During our testing, we noted 2 students, out of a sample of 9, where a return of unearned Title IV funds was not calculated even though the students withdrew and 1 out of 9 students received additional Title IV funds after a return of Title IV funds was processed. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be calculated and to return unearned portions to the Department of Education. Effect Franklin Cummings Tech did not return unearned Title IV funds. Questioned Costs $9,939 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 3 students, or 33.3% of our sample, were not calculated and processed correctly for return of unearned Title IV funds. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the process of Return of Title IV calculations for all students who withdraw to ensure that funds earned are calculated correctly and unearned portions are returned to the Department of Education properly. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 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 June 2019: 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”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 2 out of 27 students were reported late to the NSLDS by 98 days. During our testing, 1 out of 27 students reported an incorrect effective date, and 4 out of 27 students had an incorrect status reported to the NSLDS. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates and status to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 27 students selected for testing, 4 students, or 14.8% of our sample, did not report the correct effective dates and status to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.033, 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.34: (a) An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs. (9) If the institution permits a student to appeal a determination by the institution that he or she is not making satisfactory academic progress, the policy describes – (i) How the student may reestablish his or her eligibility to receive assistance under the title IV, HEA programs; (ii) The basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances; and (iii) Information the student must submit regarding why the student failed to make satisfactory academic progress, and what has changed in the student's situation that will allow the student to demonstrate satisfactory academic progress at the next evaluation. Condition Franklin Cummings Tech’s satisfactory academic progress policy (“SAP”) allows for a student who fails to meet the minimum standard to be provided one semester of academic warning. If the student does not improve, as described in Franklin Cummings Tech’s SAP, the student will be placed on academic suspension from Franklin Cummings Tech unless the student successfully appeals the academic suspension. The student placed on academic suspension will lose financial aid eligibility in the next semester. Our testing revealed that one student failed to meet the minimum standards established by Franklin Cummings Tech’s SAP but was awarded financial aid. Cause Franklin Cummings Tech failed to have proper review procedures in place to prevent students who did not meet the minimum SAP standards from receiving financial aid. Effect A student who did not meet the minimum SAP standards received financial aid. Questioned Costs $983 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5%, failed to meet the minimum standards established by Franklin Cummings Tech’s SAP, who did not receive notification. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should continue to strengthen its controls surrounding SAP policy to ensure all students who receive assistance under the title IV are making satisfactory academic progress. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(j)(1): Timeframe for the return of title IV funds. An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. According to 34 CFR 668.173(b): Timely return of Title IV, HEA program funds. In accordance with procedures established by the Secretary or Federal Family Education Loan (“FFEL”) program lender, an institution returns unearned Title IV, HEA program funds timely if – (1) The institution deposits or transfers the funds into the bank account it maintains under 34 CFR Sections 668.163 no later than 45 days after the date it determines the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower’s loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. An institution does not satisfy this requirement if – (i) The institution’s records show that the check was issued more than 45 days after the date the institution determined the student withdrew; or (ii) The date on the cancelled check shows that the bank used by the Secretary or FFEL Program lender endorsed that check more than 60 days after the date the institution determined that the student withdrew. Condition Federal regulations state that any unearned Title IV grant or loan assistance received by a student must be refunded to the Title IV programs upon a student’s withdrawal from the institution. Franklin Cummings Tech has 45 days from the date it determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted 2 students, out of a sample of 9, had unearned Title IV aid that was not returned to the Federal Government, within 45 days of the determined withdrawal date, by 45 to 90 days. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be returned to the Department of Education within 45 days. Effect Franklin Cummings Tech did not return unearned Title IV funds within the required 45-day time frame. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 2 students, or 22.2% of our sample, had unearned Title IV funds that were not returned to the Department of Education within the 45-day required time frame. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review Return of Title IV calculations in a timely manner to ensure that all funds are returned to the Department of Education within the required time frame. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 Criteria According to 34 CFR 668.22(e): (1) General. The amount of title IV grant or loan assistance that is earned by the student is calculated by— (i) Determining the percentage of title IV grant or loan assistance that has been earned by the student, as described in paragraph (e)(2) of this section; and (ii) Applying this percentage to the total amount of title IV grant or loan assistance that was disbursed (and that could have been disbursed, as defined in paragraph (l)(1) of this section) to the student, or on the student's behalf, for the payment period or period of enrollment as of the student's withdrawal date. (4) Total amount of unearned title IV assistance to be returned. The unearned amount of title IV assistance to be returned is calculated by subtracting the amount of title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The Financial Aid Department is responsible for completing the Return of Title IV calculation to determine how much Title IV funds the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, Franklin Cummings Tech is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G5”). During our testing, we noted 2 students, out of a sample of 9, where a return of unearned Title IV funds was not calculated even though the students withdrew and 1 out of 9 students received additional Title IV funds after a return of Title IV funds was processed. Cause Franklin Cummings Tech did not consistently follow the procedures in place to monitor student withdrawals related to Title IV funds that must be calculated and to return unearned portions to the Department of Education. Effect Franklin Cummings Tech did not return unearned Title IV funds. Questioned Costs $9,939 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 9 students selected for testing, 3 students, or 33.3% of our sample, were not calculated and processed correctly for return of unearned Title IV funds. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the process of Return of Title IV calculations for all students who withdraw to ensure that funds earned are calculated correctly and unearned portions are returned to the Department of Education properly. View of Responsible Officials Franklin Cummings Tech agrees with the finding.

Finding number: 2023-04 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2023 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 June 2019: 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”). The 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 student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires Franklin Cummings Tech to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 2 out of 27 students were reported late to the NSLDS by 98 days. During our testing, 1 out of 27 students reported an incorrect effective date, and 4 out of 27 students had an incorrect status reported to the NSLDS. Cause Franklin Cummings Tech did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely and correctly. Effect Franklin Cummings Tech did not report the students’ correct effective dates and status to NSLDS or were not reported within the required timeframe, which may impact the students’ loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 27 students selected for testing, 4 students, or 14.8% of our sample, did not report the correct effective dates and status to NSLDS or were not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation Franklin Cummings Tech should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Franklin Cummings Tech agrees with the finding.