Audit 325860

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 668.22, states that when students withdraw from a school, institutions are required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing it was noted that: 24 of 110 students tested resulted in a overpayment of $1,151 and underpayment of $3,124 of funds that should have been returned to the students based on individual students’ R2T4 calculation but was not. This lead to cumulative question costs of $1,973. Questioned Costs: $1,151 overpayment; $3,124 underpayment Context: The College incorrectly calculated the break days for all R2T4’s in the spring semester. Cause: The College has had turnover and there was no oversight over the withdrawal process and calculation of R2T4. Effect: There are questioned costs of $1,973. Repeat Finding: No. Auditors’ Recommendation We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 690.65 states that the total loan amount that the student may receive for the program (or remaining portion of the program) at the new school (for the abbreviated loan period and any subsequent loan period combined) may not exceed the applicable prorated annual loan limit for the program or remaining portion of the program. Condition: During our testing, we noted that one of 40 students tested was over awarded subsidized and unsubsidized direct loan funds. Questioned Costs: $9,500 Context: The College awarded a transfer student awarded subsidized and unsubsidized direct loan funds when they had already been awarded these funds at their prior institution. Cause: Lack of controls around awarding transfers with in SFA. Effect: There are questioned costs of $9,500 Repeat Finding: No Auditor’s Recommendation: We recommend the College evaluate the transfer students’ status each semester. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 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 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing, it was noted 3 of 40 students effective date per the institutions record and the NSLDS effective date not to match. The College did not have a proper system in place to ensure the NSC was reporting the student to NSLDS properly. The institution also must update all records every 60 days, and CLA noted 1 out of 40 students had instances greater than 60 days where their records were not updated. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution’s records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the College's records. Finally, Updates to NSLDS were not completed in a timely manner. Cause: The College has had turnover, and they did not have a proper system in place to ensure the NSC was reporting the students to NSLDS properly. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: No Auditor’s Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.