Audit 329180

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 instance out of 40 students tested where the subsidized Stafford loan awarded to the student was less than the maximum amount they were eligible for. Questioned Costs: $103 Context: The student's award package was updated in the Spring which resulted in more need based aid. The $103 was disbursed as unsub loans instead of sub loans. Cause: The University did not have sufficient processes in place to identify the correct award. Effect: The student did not receive enough need based aid. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University evaluate its procedures and a policy around how changes in status or inputs are handled when packaging and awarding students. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.038 – Federal Perkins Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution was not able to perform their due diligence for fiscal year 2024 since the third party service provider’s 2024 Title IV compliance audit was not completed as of issuance of audit. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2024 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states schools must have some arrangement to report student enrollment data to NSLDS through an enrollment roster file. The school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 day. There are two categories of enrollment information; "Campus Level" and "Program Level," both of which need to be reported accurately and have separate record types. Condition: During our testing we noted the following errors in NSLDS recording. 1.) 24 out of 60 students had effective dates per the institutions record that did not match the effective date in NSLDS. 2.) 6 out of the 60 students had had instances greater than 60 days where their records were not updated. 3.) 2 out of the 60 students had "No Record Found" per NSLDS screenshots due to errors made by the institution with reporting to NSC. Errors were not corrected. Questioned Costs: None Context: The enrollment roster file contained dates that were incorrect for the Enrollment and Program Level effective dates. In the cases of this error the enrollment information should have been the date per institution's records for the Campus and Program Level. There were also instances where the information on the Enrollment and Program level were inconsistent with the University's records. Finally, Updates to NSLDS were not completed in a timely manner and some were not updated at all. Cause: The University has had significant turnover and updates were missed. Effect: The NSLDS system is not updated with the student information which can cause a student to not properly enter the repayment period. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations 34 CFR 668.22, states that when students withdraw from a school, institutions is required to determine earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a pro rate schedule is used to determine the amount of Title IV funds the students earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. Condition: During our testing we noted that following errors in R2T4 reporting: 1) 5 of the 60 students not returned funds with in 45 days. 2) 2 out of 60 students tested did not have R2T4 calculations performed despite the fact that they attended classes and had all their aid returned. This resulted in $71.81 that was earned by the students improperly being returned. Questioned Costs: $71.81 Context: The University did not properly calculate R2T4's or timely return funds in all cases where it should have. Cause: The University did not have proper procedures in place to correctly calculate and timely return appropriate funds. Effect: Funds were not disbursed to students as they should have been and funds were not timely returned to the Department. Repeat Finding: Yes Auditors’ Recommendation: We recommend that the University implement a review process as it relates to R2T4. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Department of Education requires the College to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Condition: During our testing, we noted 2 of the 40 disbursements tested had incorrect disbursement dates reported to the Common Origination and Disbursement (COD) system. Questioned Costs: None Context: The University did not have an effective process in place to timely report disbursements to COD. Cause: The University does not have a process in place to accurate report Pell disbursements to COD within the required 15 days. Effect: The University is not in compliance with Department of Education regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work Study Program 84.038 – Federal Perkins Loans 84.063 – Federal Pell Grant Program 84.268 – Federal Direct Student Loans 84.379 – Teacher Education Assistance for College and Higher Education Grants Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 668.164(h) states a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but - (1) No later than 14 days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (2) No later than 14 days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: During our testing of credit balances resulting from federal funds, we noted 1 credit balance out of 40 tested where the credit balance was not refunded within the 14 day period. Questioned Costs: $366 Context: The University did not have a system in place to timely return refunds to students. Cause: The University did not have a review process in place to ensure all credit balances are refunded within the 14 day period. Effect: The University did not refund students within 14 days for credit balances that arose from federal funds as required by ED regulations. Repeat Finding: No Auditors’ Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 – Federal Direct Student Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: The Code of Federal Regulations, 34 CFR 685.203(a) outline the maximum subsidized loan amounts for students based on their dependency status, year of education, and other factors. Condition: During our testing, we noted 1 instance out of 40 students tested where the subsidized Stafford loan awarded to the student was less than the maximum amount they were eligible for. Questioned Costs: $103 Context: The student's award package was updated in the Spring which resulted in more need based aid. The $103 was disbursed as unsub loans instead of sub loans. Cause: The University did not have sufficient processes in place to identify the correct award. Effect: The student did not receive enough need based aid. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University evaluate its procedures and a policy around how changes in status or inputs are handled when packaging and awarding students. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.038 – Federal Perkins Loans Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: 2 CFR 200.303 Code of Federal Regulations Title 34, Subtitle B, Chapter VI, Part 674.19 requires that in administering its Federal Perkins Loan program, an institution shall establish and maintain an internal control system of checks and balances that ensures that no office can both authorize payments and disburse funds to students. When an institution uses a third-party servicer for its Perkins Loan program, the institution must perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Such due diligence could include obtaining and reviewing the third-party servicer’s most recent Title IV compliance audit. Condition: The University utilizes a third party service provider for its Perkins Loan servicing. Federal regulations require the institution to perform due diligence on the third party servicer to ensure they are following federal regulations. The institution was not able to perform their due diligence for fiscal year 2024 since the third party service provider’s 2024 Title IV compliance audit was not completed as of issuance of audit. Questioned Costs: None Context: The due diligence typically performed by the institution is the review of the third party servicer's compliance report. However, the third party servicer was delayed in having this report issued. The institution did not have an alternate plan for performing due diligence over the third party servicer. Cause: The third party servicer, did not have their Title IV compliance audit report completed for the year ending June 30, 2024 so that the University could perform their required due diligence on the third party servicer and the institution did not have an alternate plan established. Effect: The University did not perform due diligence to ensure that the third-party service is in compliance with the requirements for the functions the third-party servicer is performing for the institution. Repeat Finding: Yes Auditors’ Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding.