Audit 324498

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-005 – NSLDS Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS. Questioned Costs: None Context: Out of a sample of 40 students selected for testing, we noted the following: • 3 students were reported with the incorrect enrollment status at both the campus and program levels. • The status change for 6 students was not reported timely to NSLDS • The program begin date for 5 students were incorrectly reported at the program level Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, prior year finding 2023-007. Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-002 – Direct Loan Reconciliations Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly. Condition: Direct loan reconciliations between the Common Origination and Disbursement (COD), G5 and student accounts were not documented as performed during the year. Questioned Costs: None Context: While testing direct loan reconciliations, it was noted that the University was reconciling direct loan activity on nearly a daily basis. However, the University did not maintain supporting documentation that the reconciliation process took place. Cause: There was turnover at the University and not all documentation was maintained or could be located. Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support performance on a monthly basis. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-005 – NSLDS Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS. Questioned Costs: None Context: Out of a sample of 40 students selected for testing, we noted the following: • 3 students were reported with the incorrect enrollment status at both the campus and program levels. • The status change for 6 students was not reported timely to NSLDS • The program begin date for 5 students were incorrectly reported at the program level Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, prior year finding 2023-007. Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-005 – NSLDS Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS. Questioned Costs: None Context: Out of a sample of 40 students selected for testing, we noted the following: • 3 students were reported with the incorrect enrollment status at both the campus and program levels. • The status change for 6 students was not reported timely to NSLDS • The program begin date for 5 students were incorrectly reported at the program level Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, prior year finding 2023-007. Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-002 – Direct Loan Reconciliations Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.300(b)(5) requires an institution to reconcile their records with the Direct Loan funds received from the Secretary and the Direct Loan disbursement records submitted to and accepted by the Secretary monthly. Condition: Direct loan reconciliations between the Common Origination and Disbursement (COD), G5 and student accounts were not documented as performed during the year. Questioned Costs: None Context: While testing direct loan reconciliations, it was noted that the University was reconciling direct loan activity on nearly a daily basis. However, the University did not maintain supporting documentation that the reconciliation process took place. Cause: There was turnover at the University and not all documentation was maintained or could be located. Effect: The University is not complying with internal policy and federal requirements to ensure funds are properly reconciled. Repeat Finding: Yes, prior year finding 2023-002. Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support performance on a monthly basis. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-005 – NSLDS Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.268 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Per U.S. Department of Education (ED) regulations, all schools participating (or approved to participate) in the Federal Student Aid programs must have an arrangement to report student enrollment data to the NSLDS through a roster file. The school is required to report enrollment status at both the school and program level. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. An academic program is defined as the combination of the school’s Office of Postsecondary Education Identification (OPEID) number and the program’s Classification of Instructional Program (CIP) code, credential level, and published program length. ED requires the University to report changes in enrollment status and indicate the date that the changes occurred (34 CFR 685.309). Condition: During our testing, we noted instances where student enrollment status changes were incorrectly reported to NSLDS. Questioned Costs: None Context: Out of a sample of 40 students selected for testing, we noted the following: • 3 students were reported with the incorrect enrollment status at both the campus and program levels. • The status change for 6 students was not reported timely to NSLDS • The program begin date for 5 students were incorrectly reported at the program level Cause: Due to turnover in the Registrar’s office, status changes were not reported accurately. Effect: Inaccurate reporting to the NSLDS can result in incorrect determination of when the students’ grace period should begin. Repeat Finding: Yes, prior year finding 2023-007. Recommendation: The University should review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Views of Responsible Officials: Management agrees with the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379 & 84.033 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outlines the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 of 36 students was not awarded the correct subsidized loan amount based off their dependency status and year of education. Questioned Costs: $500 Context: During our testing, the student’s Title IV was auto-packaged and did not correctly factor in all the student's credits resulting in an under award of subsidized loan funds. Cause: The University did not package Title IV funds correctly based on dependency status and year of education. Effect: The student was eligible for more subsidized loan funds than awarded. Repeat Finding: No. Recommendation: We recommend the University evaluate its procedures and policies around packaging Title IV based on need. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.

2024-003 – Verification Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.56 requires institutions to obtain supporting documentation and perform verification procedures for students selected by the Central Processing System (CPS). Supporting documents must be retained to support the results of students selected for verification. 34 CFR 668.57 lists the acceptable documentation to be obtained for the verification procedures. Condition: During our testing, 2 of 9 students did not have the required support in their student files. Questioned Costs: None Context: During our testing, the University was unable to locate the Statement of Educational Purpose and other supporting verification documentation for 2 of 9 students. Cause: The University’s processes and controls did not ensure the information obtained and utilized for verification purposes was retained in the files. Effect: The University is not maintaining proper documentation in student files. Repeat Finding: Yes, prior year finding 2023-003. Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained and retained in the student files. Views of Responsible Officials: Management agrees with the finding.

2024-004 – Return of Title IV (R2T4) Funds Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Federal Assistance Listing Number: 84.063, 84.007, 84.268, 84.379, 84.033, & 84.038 Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: For a student who ceases attendance at an institution that is required to take attendance, including a student who does not return from an approved leave of absence, the student's withdrawal date is the last date of academic attendance as determined by the institution from its attendance record (34 CFR 668.22(b)(1)). Condition: During our testing, the incorrect scheduled end date and number of days in scheduled breaks were used in the R2T4 calculations. Questioned Costs: $4,068 Context: During our testing, 3 of 5 instances were noted where the University mistakenly put the incorrect semester end date and incorrect number of days in scheduled breaks. Cause: R2T4 calculations are not being accurately performed. Effect: The University did not complete an accurate calculation as defined by Federal Regulations. Repeat Finding: Yes, prior year finding 2023-006. Recommendation: We recommend the University review all R2T4 calculations to ensure the correct end date and number of scheduled break days are being used for all Title IV aid. Views of Responsible Officials: Management agrees with the finding.