Audit 327688

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P230097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their EFC and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. All Schedules, however, are based on the COA of a full-time student for a full academic year (see Volume 7, The Federal Pell Grant Program and Iraq and Afghanistan Service Grants, of the FSA Handbook for 2023-24 for guidance on selecting formulas for calculating cost of attendance, prorating costs for programs less or greater than an academic year and determining payment periods). Disbursement schedules for 20222023 and 2023-2024 award years can be found at the following links: 2022-2023 Federal Pell Grant Payment and Disbursement Schedules (GEN-22-04) and 2023-2024 Federal Pell Grant Payment and Disbursement Schedules (GEN-23-02). Students that receive Pell Grant may not receive more than six Scheduled Awards (12 semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU) field in COD (tracked by ED) (20 USC 1070a(c)(5)). The LEU maximum percentage for student eligibility is 600 percent. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing our testing of return of Title IV funds, one student had been awarded Pell when they were not eligible to receive Pell due to the timing of the award. Context: During our Return of Title IV testing, we selected forty samples to test. While testing eligibility was not the focus of this test, the University brought to our attention one exception of a student being awarded Pell when they were not eligible to receive Pell due to the timing of the award. We also tested 40 other students in our eligibility testing in which no exceptions were identified. Questioned costs: $1,879. Effect: The University was out of compliance with the requirement to properly award students Title IV funds based on eligibility. Additionally, the University was out of compliance as it relates to properly calculating the return of Title IV funds. Cause: Per discussion with the University, Pell was awarded erroneously and a review process did not identify the issue prior to disbursing the aid. Repeat finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds to ensure only eligible students are receiving funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 & 84.268 Federal Award Identification Number and Year: P063P230097 & P268K240097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct Loan programs via the National Student Loan Data System (NSLDS) (OMB No. 1845-0035) (Pell, 34 CFR 690.83(b)(2); Direct Loan, 34 CFR 685.309.) The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and certify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (NSLDSFAP) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment. 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. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of the accuracy of NSLDS reporting, we identified eight out of forty samples where the program effective date per institutional records did not match the program effective date reported in NSLDS. Context: Out of 40 students tested, we identified eight students in which the program effective date per institutional records did not match the program effective date reported in NSLDS. Questioned costs: None.Effect: The University was out of compliance as it relates to ensuring the program effective date reported in NSLDS matches institutional records. Cause: The program effective dates per institutional records not matching program effective date per NSLDS program enrollment was due to either and old admissions software or the Online Major Change (OMC) tool. Repeat finding: No. Recommendation: We recommend the University review its current procedures for NSLDS reporting and implement additional procedures to ensure program effective dates in NSLDS match institutional records. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. 34 CFR 668.22(B)(2) states, an institution must document a student's withdrawal date determined in accordance with paragraph (b)(1) and maintain the documentation as of the date of institution's determination that the student withdrew. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing of timely and accurate return of Title IV funds, we identified one out of 40 samples that the return of Title IV funds was later than 45 days after the institution's determination that the student withdrew. Additionally, one out of 40 samples did not have documentation for the student's withdrawal date used for the return of Title IV calculation.Context: We selected forty samples to test which resulted in two exceptions: 1. One had the return of Title IV funds later than 45 days after the institution's determination that the student withdrew, and 2. One did not have documentation for the student's withdrawal date used for the return of Title IV calculation. Questioned costs: $270 Effect: The University had two elements of noncompliance as it relates to the Department of Education’s many requirements of returning Title IV funds. Cause: Of the two exceptions: 1. A student’s Title IV funds were returned 65 days after the institutional determination. Per discussion with the University, the daily query being used to process disbursements in the Fall semester wasn’t coming through over the weekend as it should have been. Upon discussion with the University, this impacted the timeliness of two other students not tested. 2. A student’s documentation of withdrawal date was not retained by the University due to a former staff member not asking other department employees to contact instructors for Last Date of Attendance for an officially withdrawn course. They instead used the date the course was officially dropped in self-service. Repeat finding: No. Recommendation: We recommend the University review its current procedures for return of Title IV funds. As part of the review, the University should implement safeguard to ensure refunds are returned timely and that refund amounts are supported by having documentation of withdrawal dates. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 Federal Award Identification Number and Year: P063P230097 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment Schedule provides the maximum scheduled award a student would receive for a full academic year as a full-time student based on their EFC and COA. The Disbursement Schedules are used to determine annual awards for full-time, three-quarter time, half-time, and less-than-half-time students. All Schedules, however, are based on the COA of a full-time student for a full academic year (see Volume 7, The Federal Pell Grant Program and Iraq and Afghanistan Service Grants, of the FSA Handbook for 2023-24 for guidance on selecting formulas for calculating cost of attendance, prorating costs for programs less or greater than an academic year and determining payment periods). Disbursement schedules for 20222023 and 2023-2024 award years can be found at the following links: 2022-2023 Federal Pell Grant Payment and Disbursement Schedules (GEN-22-04) and 2023-2024 Federal Pell Grant Payment and Disbursement Schedules (GEN-23-02). Students that receive Pell Grant may not receive more than six Scheduled Awards (12 semesters, or the equivalent) as measured by the percentage of “lifetime eligibility used” (LEU) field in COD (tracked by ED) (20 USC 1070a(c)(5)). The LEU maximum percentage for student eligibility is 600 percent. Per 2 CFR 200.303, entities must establish and maintain internal controls which provide reasonable assurance that federal award expenditures are in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During testing our testing of return of Title IV funds, one student had been awarded Pell when they were not eligible to receive Pell due to the timing of the award. Context: During our Return of Title IV testing, we selected forty samples to test. While testing eligibility was not the focus of this test, the University brought to our attention one exception of a student being awarded Pell when they were not eligible to receive Pell due to the timing of the award. We also tested 40 other students in our eligibility testing in which no exceptions were identified. Questioned costs: $1,879. Effect: The University was out of compliance with the requirement to properly award students Title IV funds based on eligibility. Additionally, the University was out of compliance as it relates to properly calculating the return of Title IV funds. Cause: Per discussion with the University, Pell was awarded erroneously and a review process did not identify the issue prior to disbursing the aid. Repeat finding: No. Recommendation: We recommend the University review its current procedures for awarding Title IV funds to ensure only eligible students are receiving funds. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Federal Agency: U.S. Department of Justice Federal Program Title: Postconviction Testing of DNA Evidence; Capital Case Litigation Initiative Assistance Listing Number: 16.820; 16.746 Federal Award Identification Number and Year: Multiple Award Period: July 1, 2023 to June 30, 2024 Type of Finding: 􀁸 Other Matters 􀁸 Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.516(4): Known questioned costs that are greater than $25,000 for a Federal program which is not audited as a major program should be reported as finding. Except for audit follow-up, the auditor is not required under this part to perform audit procedures for such a Federal program; therefore, the auditor will normally not find questioned costs for a program that is not audited as a major program. However, if the auditor does become aware of questioned costs for a Federal program that is not audited as a major program (e.g., as part of audit follow-up or other audit procedures) and the known questioned costs are greater than $25,000, then the auditor must report this as an audit finding. Additionally, per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. CFR 200.403(a) requires costs incurred on federal awards to be necessary and reasonable for the performance of the Federal award and be allocable thereto. Condition: CLA was notified by the Post-Award Office of Sponsored Programs that they were informed about several irregularities and potentially unallowable costs related to certain Department of Justice Awards. Context: The University conducted an internal investigation in conjunction with the Idaho State Board of Education Internal Audit and Advisory Services, the investigation identified unallowable costs/activities that were charged to Department of Justice Awards. The University notified the Department of Justice of this situation through a Disclosure Letter to the Department. The disallowed costs were related to time and effort that was not allocable to the affected grants as well as lobbying efforts and related indirect cost recoveries. Questioned costs: $65,750.67. Effect: The University was out of compliance as it relates to charging disallowable costs/activities to federal programs. Cause: An employee was found to have intentionally overridden the system of internal controls in violation of University policy. Repeat finding: No Recommendation: We recommend the University continue to foster a research and creative activity environment that stresses the importance of compliance and prompt disclosure and resolution of any self-identified issues. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.