Audit 328453

Suspension Debarment Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: 2320040-2024 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: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the 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. Condition: The University was not able to provide a verification check occurring before entering into contract with a vendor/subrecipient. Context: During our testing of 5 contracts, we identified one vendor/subrecipient that the University could not provide a verification check prior to entering the contract. Questioned costs: None. Cause: Verification check did not occur before entering into contract with vendor/subrecipient. Effect: The University entered into contract with a vendor/subrecipient prior to performing a verification check. Repeat finding: Yes, 2023-004 Recommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 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: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the 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. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Procurement Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: CE2559-SB-873905 A2, A3 - 2024 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: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. In addition, per the Uniform Guidance 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. Condition: The University did not complete documentation for reasonings of why they did not obtain price quotes or competitive bids prior to entering the transaction. Context: During our testing we identified 1 of the 5 contracts tested did not include adequate documentation to award the contracts without price quotations or a competitive bid process. Questioned costs: $39,160 Cause: Lack of training for procurement personnel regarding federal funds passed through State agencies to the University. Effect: Documentation for why the University did not obtain price quotes or competitive bids was not documented in a timely manner. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for not obtaining price quotes or competitive bids prior to entering the transaction. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 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: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 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: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 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: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the 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. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Suspension Debarment Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: 2320040-2024 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: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the 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. Condition: The University was not able to provide a verification check occurring before entering into contract with a vendor/subrecipient. Context: During our testing of 5 contracts, we identified one vendor/subrecipient that the University could not provide a verification check prior to entering the contract. Questioned costs: None. Cause: Verification check did not occur before entering into contract with vendor/subrecipient. Effect: The University entered into contract with a vendor/subrecipient prior to performing a verification check. Repeat finding: Yes, 2023-004 Recommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 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: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the 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. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Procurement Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: CE2559-SB-873905 A2, A3 - 2024 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: The Federal Government requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of 2 CFR section 200.319 and 2 CFR section 200.320. In addition, per the Uniform Guidance 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. Condition: The University did not complete documentation for reasonings of why they did not obtain price quotes or competitive bids prior to entering the transaction. Context: During our testing we identified 1 of the 5 contracts tested did not include adequate documentation to award the contracts without price quotations or a competitive bid process. Questioned costs: $39,160 Cause: Lack of training for procurement personnel regarding federal funds passed through State agencies to the University. Effect: Documentation for why the University did not obtain price quotes or competitive bids was not documented in a timely manner. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures and implement an additional control to document reasons for not obtaining price quotes or competitive bids prior to entering the transaction. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 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: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Eligibility - Pell Federal Agency: Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063 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: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure students are awarded and disbursed the proper federal fund amounts. Condition: The University under-awarded funds for the Pell Grant. Context: During our testing we noted one of forty students, from a statistically valid sample, were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Questioned costs: None Cause: The report generated to capture Summer term students who did not self-identify for Summer Aid consideration but qualified for Pell funds did not capture this student due to system changes that were not accounted for in the SQL. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat finding: No Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Special Tests & Provisions Federal Agency: 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: The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of 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 days. In addition per the Uniform Guidance 2 CRF 200.303, non- federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified two instances for which the student’s enrollment status was not correctly reported to NSLDS in a timely manner and one instance where the enrollment effective date was not reported correctly to NSLDS. Questioned costs: None Cause: The University did not have proper procedures in place to verify students status in NSLDS matched the institutions records in a timely manner. Effect: Failure to properly report enrollment status changes on NSLDS could affect the timing of the grace period for repayment of Title IV loans. Additionally, the University was not in compliance with the requirements to properly report student enrollment data correctly or timely to NSLDS. Repeat finding: Yes, 2023-007 Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the University implement formal review procedures to document the review process. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Cash Management-Subrecipient Federal Agency: U.S. Federal Government Federal Program Title: Research and Development Cluster Assistance Listing Number: 93.859; 47.074 Federal Award Identification Number and Year: 1R01GM137083 – 2024; 2317969 - 2024 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: The Federal Government requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper (2 CFR section 200.305(b)(4)). In addition, per the 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. Condition: The University did not make payment to Subrecipients within the required 30 calendar days after receipt of the billing. Context: Three subrecipient invoices, totaling $29,306, out of 5 tested, totaling $60,038, were not paid within the required 30 days. Questioned costs: None. Cause: Procedures were not in place to ensure subrecipients were paid within 30 days of receipt of the invoices. Effect: Subrecipients did not receive their reimbursement timely. Repeat finding: Yes, 2023-002 Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.